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

Case 1:07-cv-00285-MMS

Document 23

Filed 07/18/2008

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

JOINT MOTION FOR ENLARGEMENT OF TIME TO FILE THE PARTIES' FOURTH JOINT STATUS REPORT Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, the parties, by stipulation, hereby respectfully move for an enlargement of two (2) business days for the filing of the Fourth Joint Status Report. The parties respectfully request that the Fourth Joint Status Report be due no later than July 22, 2008. See Exhibit 1. The Fourth Joint Status Report is currently due July 18, 2008. No enlargements of time for the filing of this document have been requested. The additional time is needed for defendant to coordinate its positions on the matters to be contained in the Fourth Joint Status Report. Counsel for defendant and counsel for plaintiff are in agreement that this motion should be granted. See Exhibit 1. WHEREFORE, for the reasons stated above, the parties respectfully request that they be granted an enlargement of time of two (2) business days, or to and including July 22, for the filing of the Fourth Joint Status Report.

Case 1:07-cv-00285-MMS

Document 23

Filed 07/18/2008

Page 2 of 2

Dated: July 18, 2008.

Respectfully submitted by defendant on behalf of the parties, RONALD J. TENPAS Acting Assistant Attorney General Environment and 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) 305-0274