Free Motion for Leave to File Out of Time - District Court of Federal Claims - federal

Case 1:06-cv-00401-NBF

Document 24

Filed 06/16/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) Plaintiff, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________) JILLINA MANION,

No. 06-401L Hon. Nancy B. Firestone

JOINT MOTION FOR LEAVE TO FILE OUT OF TIME ________________________________________________________________________ The parties respectfully move this Court for leave to file out of time the attached Joint Motion to Enlarge the Discovery Period in the above reference matter. Exhibit A. Pursuant to the Court's April 9, 2008 Order, discovery ended on June 9, 2008. (Docket No. 22). Because the parties are in agreement, the granting of this unopposed motion to file seven days out of time would not cause any undue prejudice or harm to the rights and interests of the parties. WHEREFORE, Defendant respectfully requests that the Court grant the parties leave to file out of time their Joint Motion to Enlarge the Discovery Period.

Case 1:06-cv-00401-NBF

Document 24

Filed 06/16/2008

Page 2 of 2

Respectfully submitted by Defendant on behalf of the parties this 16th day of June, 2008, RONALD J. TENPAS Assistant Attorney General Environment and Natural Resources Division

s/ Mark T. Romley Mark T. Romley Trial Attorney Natural Resources Section Environment & Natural Resources Division United States Department of Justice P. O. Box 663 Washington, D.C. 20044-0663 Telephone: (202) 305-0458 Fax: (202) 305-0506 Counsel for Defendant.