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

Case 1:06-cv-00288-CCM

Document 16

Filed 12/20/2006

Page 1 of 3

UNITED STATES COURT OF FEDERAL CLAIMS

PEOPLE OF BIKINI, BY AND THROUGH THE KILI/BIKINI/EJIT LOCAL GOVERNMENT COUNCIL, Plaintiffs, v. THE UNITED STATES, Defendant.

) ) ) ) ) ) ) ) ) ) )

No. 06-288C (Judge Block)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests an enlargement of time of 28 days, to and including January 30, 2007, within which to file our reply to plaintiffs' opposition to defendant's motion to dismiss. Our reply brief currently is due on January 2, 2007. This is defendant's first request for an enlargement of time to file our reply brief. Plaintiffs' counsel does not oppose this request. Plaintiffs filed their response brief on December 18, 2006. Undersigned defendant's counsel promptly forwarded a copy of the brief to the interested agencies. However, in light of the upcoming holidays and leave plans of involved Government counsel, we will be unable to prepare a draft brief, circulate it among the interested agencies, and receive and incorporate any comments upon the brief within sufficient time to prepare and file our reply brief by January 2, 2007.1

Undersigned counsel is scheduled to be on annual leave from December 22, 2006 to January 2, 2007. Counsel for the interested agencies also are scheduled to be on leave during this period.

1

Case 1:06-cv-00288-CCM

Document 16

Filed 12/20/2006

Page 2 of 3

Accordingly, we respectfully request that the Court grant this unopposed motion for enlargement until January 30, 2007, to prepare and file our reply brief.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General s/ David M. Cohen DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director U.S. Department of Justice Civil Division Commercial Litigation Branch 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Tele: (202) 307-6288 Fax: (202) 514-8640 E-mail: [email protected] Attorneys for Defendant December 20, 2006

2

Case 1:06-cv-00288-CCM

Document 16

Filed 12/20/2006

Page 3 of 3

Certificate of Filing I hereby certify that on December 20, 2006, a copy of foregoing "Defendant's Unopposed Motion for 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. Parties may access this filing through the Court's system.

s/ Kathryn A. Bleecker