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

Case 1:07-cv-00271-RHH

Document 66

Filed 06/19/2008

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 ENLARGEMENTS OF TIME ______________________________________________________ The United States, pursuant to RCFC 6(b), requests enlargements of time in which to file its reply in support of its motion to stay and its reply in support of its motion for summary judgment. Specifically, the United States requests an enlargement of time of four days to file its reply in support of its motion to stay (currently due June 23, 2008) and an enlargement of time of seven days to file its reply in support of its motion for summary judgment (currently due June 26, 2008). The United States requests these enlargements of time because counsel for the United States have several other near-term court filings in other cases. Accordingly, the United States respectfully requests that the Court grant it (1) a four-day enlargement of time, until June 27, 2008, to file its reply in support of its motion to stay, and (2) a seven-day enlargement of time, until July 3, 2008, to file its reply in support of its motion for summary judgment. The United States has not previously sought extensions of time to file either reply. The extensions will not impact the parties' abilities to meet future deadlines in this case.

Case 1:07-cv-00271-RHH

Document 66

Filed 06/19/2008

Page 2 of 2

Counsel for the United States contacted Plaintiffs' counsel regarding this request. Plaintiffs' counsel does not oppose the granting of this motion. June 19, 2008 Respectfully submitted, RONALD J. TENPAS Acting Assistant Attorney General Environmental & Natural Resources Division /s/ Rachel A. Dougan RACHEL A. DOUGAN JAMES D. GETTE Trial Attorneys Natural Resources Section Environment and Natural Resources Division United States Department of Justice Benjamin Franklin Station, P.O. Box 663 Washington, DC 20044-0663 Telephone: (202) 616-5082 Facsimile: (202) 305-0506 [email protected]

Of Counsel: ELLEN D. HANSON, General Counsel EVELYN KITAY, Attorney Surface Transportation Board Office of General Counsel 395 E Street, SW Washington, DC 20024

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