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

Case 1:07-cv-00184-LAS

Document 25

Filed 11/20/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ________________________________________________ ) THE PEOPLE OF THE STATE OF CALIFORNIA ) EX REL. EDMUND G. BROWN JR., ATTORNEY ) GENERAL OF THE STATE OF CALIFORNIA, and the ) CALIFORNIA DEPARTMENT OF WATER ) RESOURCES BY AND THROUGH ITS ) CALIFORNIA ENERGY RESOURCES SCHEDULING ) DIVISION, ) ) Plaintiffs, ) ) v. ) No. 07-184C ) (Senior Judge Smith) ) THE UNITED STATES, ) ) Defendant. ) ________________________________________________) DEFENDANT'S UNOPPOSED MOTION TO ENLARGE TIME TO RESPOND TO CALIFORNIA'S MOTION TO COORDINATE PRETRIAL PROCEEDINGS Defendant respectfully requests an enlargement of time of 7 days, to and including December 3, 2007, within which to file our response to plaintiffs' motion to coordinate pretrial proceedings. Our response is now due to be filed on November 26, 2007. This is defendant's first request for an enlargement of time for this purpose. Counsel for plaintiffs has represented that plaintiffs do not oppose an enlargement of time. Defendant's counsel has been out of the office on unanticipated leave this week and has been unable to complete a draft of the Government's response. Government counsel assisting counsel of record will also be out of the office this week on previously scheduled leave and is unable to participate in drafting the Government's response. A one-week enlargement will permit us enough time to draft our response and obtain necessary supervisory review. Accordingly, we request that our motion to enlarge be granted.

Case 1:07-cv-00184-LAS

Document 25

Filed 11/20/2007

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General s/ Jeanne E. Davidson by Bryant G. Snee JEANNE E. DAVIDSON Director OF COUNSEL: Sean B. McNamara Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Peter Burger Attorney Bonneville Power Administration John D. Bremer Attorney Western Area Power Administration November 20, 2007 Attorneys for Defendant s/ Mark A. Melnick by Sean B. McNamara MARK A. MELNICK Assistant Director Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L St., NW Washington, D.C. 20530 Tele: (202) 616-0475 Fax: (202) 305-7644

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Case 1:07-cv-00184-LAS

Document 25

Filed 11/20/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 20th day of November, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION TO ENLARGE TIME TO RESPOND TO CALIFORNIA'S MOTION TO COORDINATE PRETRIAL PROCEEDINGS" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. The parties may access this filing through the Court's system.

s/ Mark A. Melnick by Sean B. McNamara