Free Motion for Extension of Time to File Answer - District Court of Federal Claims - federal

Case 1:07-cv-00285-MMS

Document 5

Filed 07/02/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ELIP, LLC, ) ) ) Plaintiff, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________)

Hon. Margaret M. Sweeney

No. 07-285

MOTION FOR ENLARGEMENT OF TIME IN WHICH TO FILE RESPONSE TO PLAINTIFFS' COMPLAINT ________________________________________ Defendant UNITED STATES hereby moves for an enlargement of time of 30 days, or to and including August 6, 2007, for the filing of its response to plaintiffs' Complaint in the above captioned matter. Plaintiffs' Complaint was filed on May 7, 2007, and accordingly defendant's answer thereto is currently due on July 6, 2007. No previous enlargements of time for this response have been requested. Additional time is required in order to further develop defendant's position in this matter. Plaintiff and the Federal Aviation Administration discussed this matter prior to the filing of plaintiff's Complaint. This additional time is needed in order to provide litigation counsel the necessary details of this matter as they have developed to date. Counsel for defendant has conferred with counsel for plaintiffs who has indicated plaintiff's position as follows: [Plaintiffs] will agree to a seven day extension in exchange for any and all appraisal

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Case 1:07-cv-00285-MMS

Document 5

Filed 07/02/2007

Page 2 of 2

documents [defendant] ha[s] relating to this matter. WHEREFORE, defendant respectfully requests an enlargement of time of 30 days, or to and including August 6, 2007, for the filing of its response to plaintiffs' Complaint in the above captioned matter. Dated: July 2, 2007. Respectfully submitted,

RONALD J. TENPAS Acting Assistant Attorney General Environment & Natural Resources Division

s/ Mark T. Romley Mark T. Romley Trial Attorney Natural Resources Section Environment & Natural Resources Division United States Department of Justice P. O. Box 663 Washington, D.C. 20044-0663 Telephone: (202) 305-0458 Fax: (202) 305-0506

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