Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:07-cv-00271-RHH

Document 11

Filed 09/17/2007

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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 seven (7) days, to and including October 1, 2007, in which to file a reply to Plaintiffs' response to Defendant's Motion to Dismiss Plaintiffs' Claim for Declaratory Relief. The United States' reply is currently due September 24, 2007. The United States requests this short enlargement of time because its counsel who will write the reply will be out of town on work-related travel during the week of September 17, 2007. The United States has not previously sought an extension of time to file this reply. 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 does not oppose the granting of this motion. Accordingly, the United States respectfully requests that the Court grant it a seven (7) day extension, to and including October 1, 2007, in which to file a reply to Plaintiffs' response to Defendant's Motion to Dismiss Plaintiffs' Claim for Declaratory Relief.

Case 1:07-cv-00271-RHH

Document 11

Filed 09/17/2007

Page 2 of 2

September 17, 2007

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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