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

Case 1:07-cv-00271-RHH

Document 7

Filed 06/28/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) JACK LADD and MARIE LADD, et al., ) No. 07-271 L ) ) ) Honorable Robert H. Hodges, Jr. Plaintiffs, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________) ______________________________ UNOPPOSED MOTION FOR ENLARGEMENT OF TIME ______________________________ The United States, pursuant to RCFC 6(b), requests an enlargement of time of twentynine (29) days, to and including August 10, 2007, in which to respond to Plaintiffs' First Amended Complaint. The United States' response is currently due July 12, 2007. The United States requests this short enlargement of time in order to provide litigation counsel an opportunity to consult with the Surface Transportation Board, to identify and review the records relevant to Plaintiffs' claims, and to internally coordinate the United States' position in response to the First Amended Complaint. The United States has not previously sought an extension of time to respond to Plaintiffs' First Amended Complaint. The extension will not impact the parties' abilities to meet future deadlines in this case. Counsel for the United States contacted Plaintiffs' counsel regarding this request. Plaintiffs' counsel consents to the request and does not oppose the granting of this motion. Accordingly, the United States respectfully requests that the Court grant it a twenty-nine

Case 1:07-cv-00271-RHH

Document 7

Filed 06/28/2007

Page 2 of 2

(29) day extension, to and including August 10, 2007, in which to respond to Plaintiffs' First Amended Complaint. June 28, 2007 Respectfully submitted, RONALD J. TENPAS Acting Assistant Attorney General Environment and Natural Resources Division /s/ Rachel A. Dougan RACHEL A. DOUGAN Attorney Environment and Natural Resources Division United States Department of Justice Benjamin Franklin Station, P.O. Box 663 Washington, D.C. 20044-0663 Telephone: (202) 616-5082 Facsimile: (202) 305-0506 [email protected]

2