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

Case 1:06-cv-00167-TCW

Document 7

Filed 04/24/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS OTAY MESA PROPERTY L.P., et al., Plaintiffs, v. UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-167 L

Hon. Lawrence M. Baskir

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME IN WHICH TO FILE RESPONSE TO COMPLAINT ______________________________________________ Defendant UNITED STATES hereby moves for an enlargement of time of sixty (60) days, or to and including July 3, 2006, for the filing of the United States' response to Plaintiff's complaint. At present, Defendant's response to the complaint is due May 2, 2006. No previous enlargements of time of this deadline have been requested. Defendant respectfully requests an enlargement of time of 60 days. Additional time is necessary in order to permit the client agency, the Department of Homeland Security, to complete its litigation report in this
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Case 1:06-cv-00167-TCW

Document 7

Filed 04/24/2006

Page 2 of 2

matter. In addition, additional time is necessary in order to allow counsel for Defendant sufficient time to thoroughly review and analyze the litigation report, and prepare its answer or other response to the Complaint. Finally, counsel for Plaintiff and Defendant intend to use some of this additional time to discuss in detail whether all or part of the issues in this case are amenable to Alternative Dispute Resolution. Counsel for Defendant has contacted counsel for Plaintiff who has no objection to the granting of this enlargement of time. Dated: April 24, 2006. Respectfully submitted, SUE ELLEN WOOLDRIDGE Assistant Attorney General Environment & Natural Resources Division

s/ Susan V. Cook SUSAN V. COOK Natural Resources Section Environment & Natural Resources Division Department of Justice P. O. Box 663 Washington, D.C. 20044 Telephone (202) 305-0470 Fax (202) 305-0506 Email: [email protected] 335139.1
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