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

Case 1:06-cv-00289-CCM

Document 5

Filed 05/31/2006

Page 1 of 2

UNITED STATES COURT OF FEDERAL CLAIMS ) JOHN, et al., ) ) Plaintiffs, ) v. ) ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) _________________________________________ )

No. 06-289 L

Hon. Christine O.C. Miller

UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME IN WHICH TO FILE RESPONSE TO COMPLAINT Defendant UNITED STATES hereby moves pursuant to RCFC 6(b) for an enlargement of time of sixty (60) days from the current deadline, to and including Monday, August 14, 2006, in which to respond to Plaintiff's Complaint. A response to the Complaint currently is due on Monday, June 12, 2006. This is Defendant's first request for an extension of time. This enlargement of time is necessary to permit counsel for defendant additional time to fully consider the allegations raised in Plaintiff's 54-page Complaint to formulate an appropriate response, and to coordinate that response with counsel for several federal agencies. Counsel for Plaintiffs has authorized counsel for Defendant to represent that Plaintiffs do not object to this motion for an enlargement of time. Accordingly, Defendant respectfully moves for an enlargement of time of sixty (60) days from the current deadline, to and including Monday, August 14, 2006, in which to respond to

Case 1:06-cv-00289-CCM

Document 5

Filed 05/31/2006

Page 2 of 2

Plaintiff's Complaint.

Respectfully submitted, SUE ELLEN WOOLDRIDGE Environment & Natural Resources Division Assistant Attorney General

s/ Bruce K. Trauben _________________________ Bruce K. Trauben Natural Resources Section Environment & Natural Resources Division United States Department of Justice P.O. Box 663 Washington, D.C. 20044-0663 (202) 305-0238 (phone) (202) 305-0267 (fax)

Dated: May 31, 2006

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