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

Case 1:07-cv-00014-MMS

Document 7

Filed 03/29/2007

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Karen Budd-Falen BUDD-FALEN LAW OFFICES, LLC 300 East 18th Street Post Office Box 346 Cheyenne, W yoming 82003­0346 (307) 632-5105 Telephone (307) 637-3891 Facsimile [email protected]

IN THE UNITED STATES COURT OF FEDERAL CLAIMS THE RICHARD A. FORSGREN REVOCABLE LIVING FAMILY PRESERVATION TRUST: CLAYTA FORSGREN, RICHARD A. FORSGREN, RICHARD E. FORSGREN, TERRI LYNN HAGER, and BARBARA ANN THOMPSON, TRUSTEES, Plaintiffs, v. THE UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 07-14L PLAINTIFFS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO FEDERAL DEFENDANT'S MOTION TO DISMISS

Honorable Margaret M. Sweeney

COME NOW, the Plaintiffs, by and through their undersigned attorney, Karen Budd-Falen of the Budd-Falen Law Offices, LLC, and hereby respectfully request a fourteen-day extension of time, until April 20, 2007, in which to file their response in opposition to the Federal Defendant's Motion to Dismiss for Lack of Jurisdiction and Memorandum in Support Thereof. The Federal Defendant's Motion to Dismiss and Memorandum in Support Thereof was filed on March 12, 2007. The Plaintiffs' response in opposition is currently due to the Court no later than April 6, 2007. The Plaintiffs, however, request an enlargement of time through April 20, 2007, to respond to the Electronically Filed on March 29, 2007

Case 1:07-cv-00014-MMS

Document 7

Filed 03/29/2007

Page 2 of 3

Federal Defendant's Motion to Dismiss and Memorandum in Support Thereof. No previous extension has been requested nor granted in this matter. The enlargement of time is necessary due to a pressing workload on behalf of the Plaintiffs' counsel and a previously scheduled leave of absence during March 16-23, 2007, which has precluded the Plaintiffs' counsel from reviewing the Federal Defendant's Motion to Dismiss at this time. Accordingly, the enlargement of time is appropriate in order for the Plaintiffs to evaluate the Federal Defendant's Motion to Dismiss and draft a concise and appropriate reply thereto. In accordance with Rule 6.1, on March 29, 2007, counsel for the Plaintiffs conferred with the counsel for the Federal Defendants, Bruce K. Trauben, Trial Attorney, United States Department of Justice. Mr. Trauben does not oppose the Plaintiffs' request for an extension of time as set forth herein. WHEREFORE, the Plaintiffs respectfully request that the Plaintiffs be permitted a fourteen-day extension of time, until April 20, 2007, to respond to the Federal Defendant's Motion to Dismiss. RESPECTFULLY SUBMITTED this 29th day of March, 2007.

/s/ Karen Budd-Falen Karen Budd­Falen Budd­Falen Law Offices, LLC 300 East 18th Street Post Office Box 346 Cheyenne, Wyoming 82003­0346 (307) 632­5105 Telephone (307) 637­3891 Facsimile [email protected] Attorney for Plaintiffs -2-

Case 1:07-cv-00014-MMS

Document 7

Filed 03/29/2007

Page 3 of 3

CERTIFICATE OF SERVICE I, the undersigned, certify that I caused a true and correct copy of the foregoing to be electronically transmitted on this 29th day of March, 2007 to the following: Bruce K. Trauben Trial Attorney Natural Resources Section Environment & Natural Resources Division United States Department of Justice P.O. Box 663 Washington, D.C. 20044-0663 [email protected]

/s/ Karen Budd-Falen

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