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

Case 1:06-cv-00932-ECH

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Filed 07/25/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) ____________________________________) AK-CHIN INDIAN COMMUNITY,

Case No. 06-0932L-ECH Judge Emily C. Hewitt Electronically filed on July 25, 2007

CONSENT MOTION BY DEFENDANT FOR ENLARGEMENT OF TIMEWITHIN WHICH TO FILE DEFENDANT'S MOTION TO DISMISS PURSUANT TO 28 U.S.C. § 1500 Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims (RCFC), Defendant, the United States of America, respectfully moves this Court for a seven-day enlargement of time, to and including August 6, 2007, within which to file its motion to dismiss pursuant to 28 U.S.C. § 1500. This motion is Defendant's first such motion. The grounds for this motion are as follows: 1. Pursuant to this Court's May 30, 2007, Order, the United States is to file its

motion to dismiss by July 30, 2007. 2. In part because of responsibilities in other cases pending in this Court, Defendant

anticipates needing additional time to prepare its motion and consult with agency counsel before filing its motion. 3. Defendant therefore requests a one-week extension, to and including Monday,

August 6, 2007, of the time within which its motion is due. 7. Undersigned counsel for Defendant communicated with Plaintiff's counsel of

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record, Keith Harper, Esquire, about this motion. Mr. Harper authorized undersigned counsel to state that Plaintiff consents to the requested extension. 8. Granting this motion will not prejudice any party, nor unduly delay the case.

WHEREFORE, Defendant respectfully requests that this unopposed motion for enlargement of time be granted. Respectfully submitted this 25th day of July, 2007,

RONALD J. TENPAS ACTING ASSISTANT ATTORNEY GENERAL s/Laura M.L. Maroldy Laura M.L. Maroldy United States Department of Justice Environment and Natural Resources Division Natural Resources Section P.O. Box 663 Washington, D.C. 20044-0663 Tel: (202) 514-4565 Fax: (202) 353-2021 Attorneys for Defendant

OF COUNSEL MARTIN J. LALONDE United States Department of Justice Environment and Natural Resources Division Natural Resources Section P.O. Box 663 Washington, D.C. 20044-0663 Tel: (202) 305-0247 Fax: (202) 353-2021

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ELISABETH BRANDON Office of the Solicitor United States Department of the Interior Washington, D.C. 20240 RACHEL E. HOWARD Office of the Chief Counsel Financial Management Service United States Department of the Treasury Washington, D.C. 20227

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