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


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Case 1:06-cv-00167-TCW

Document 37

Filed 09/20/2007

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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

UNOPPOSED MOTION FOR LEAVE TO FILE THIRD UNOPPOSED MOTION FOR ENLARGEMENT OF TIME AND THIRD UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE JOINT STATUS REPORT

Defendant, United States of America, hereby moves for leave of Court to file its Third Unopposed Motion for Enlargement of Time to File Joint Status Report. Defendant respectfully requests to extend the deadline to file the Joint Status Report to and including Tuesday, September 25, 2007. Pursuant to the Court's Order of September 13, 2007, the parties are scheduled to file a Joint Status Report on September 21, 2007, outlining

Case 1:06-cv-00167-TCW

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the summary judgment issues and providing the Court with three dates for a telephonic status conference. The parties have been working to complete the Joint Status Report and believed that the document would be filed by its due date. However, certain matters have arisen which require additional time to be completed. Accordingly, Defendant respectfully requests a four-day enlargement of time in order for Plaintiffs and Defendant to complete the Joint Status Report, to and including Tuesday, September 25, 2007. Counsel for Defendant has conferred with counsel for Plaintiffs, who has authorized Defendant to represent that it does not oppose the granting of this motion. Dated: September 20, 2007. Respectfully submitted, RONALD J. TENPAS Acting Assistant Attorney General Environmental & Natural Resources Division

s/ Susan V. Cook SUSAN V. COOK, Senior Attorney Natural Resources Section Environment & Natural Resources Division
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United States Department of Justice P.O. Box 663 Washington, D.C. 20044 Tele (202) 305-0470 Fax (202) 305-0506 [email protected] Counsel for Defendant
413633.1

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