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

Case 1:07-cv-00184-LAS

Document 12

Filed 06/21/2007

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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 FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant respectfully requests an enlargement of time of 15 days, to and including July 10, 2007, within which to file its reply to plaintiffs' response to its motion to stay and for more definite statement. Defendant's reply is now due to be filed on June 25, 2007. This is defendant's first request for an enlargement of time for this purpose. Defendant has contacted plaintiffs' counsel, who has indicated that plaintiffs do not oppose this request. We have begun to draft our reply, but we require more time to complete the final version. As the Court knows, these are complex cases involving numerous plaintiffs, two government agencies, and multiple fora. Because of the complexity of these cases, our commitments in other cases, and previously scheduled annual leave, we require more time to finish a draft. Upon completion of a draft, we will send a copy to the relevant agencies for their review and

Case 1:07-cv-00184-LAS

Document 12

Filed 06/21/2007

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comments. After receiving comments from the agencies, we will then submit our draft for supervisory review. Accordingly, we respectfully request that the Court grant our motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General s/ Jeanne E. Davidson JEANNE E. DAVIDSON Director OF COUNSEL: Sean B. McNamara Trial Attorney Department of Justice Peter Burger Attorney Bonneville Power Administration John D. Bremer Attorney Western Area Power Administration June 21, 2007 s/ Mark A. Melnick MARK A. MELNICK Assistant Director Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 616-0475 Fax: (202) 305-7644

Attorneys for Defendant

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Case 1:07-cv-00184-LAS

Document 12

Filed 06/21/2007

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CERTIFICATE OF FILING I hereby certify that on this 21st day of June, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" 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