Free Motion for Leave to Exceed Page Limit - District Court of Federal Claims - federal

Case 1:06-cv-00141-LAS

Document 19

Filed 09/01/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

SHELL OIL COMPANY, UNION OIL COMPANY OF CALIFORNIA, ATLANTIC RICHFIELD COMPANY, and TEXACO INC., Plaintiffs, v. UNITED STATES OF AMERICA, Defendant.

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Case No. 06-CV-141 (Senior Judge Smith)

PLAINTIFFS' UNOPPOSED MOTION TO EXCEED PAGE LIMIT Plaintiffs Shell Oil Company, Union Oil Company of California, Atlantic Richfield Company, and Texaco Inc. (collectively, "Plaintiffs") respectfully move to exceed the twenty (20) page limit under RCFC 5.2(b)(2) for their Reply Brief in Support of their Motion for Partial Summary Judgment as to Liability ("Reply Brief"). Specifically, Plaintiffs request that they be permitted to file the accompanying Reply Brief, which is twenty-six (26) pages in length. Plaintiffs have made every effort to be concise, but in order to adequately respond to the numerous issues raised by the Government in its Reply in Support of Motion to Dismiss, and Opposition to Plaintiffs' Motion for Partial Summary Judgment, filed on August 11, 2006, it is necessary to exceed the twenty-page limitation. In the interests of justice, Plaintiffs therefore respectfully request leave to exceed the applicable page limit as to its Reply Brief. Government's counsel has informed Plaintiffs' counsel that the Government does not oppose this Motion.

Case 1:06-cv-00141-LAS

Document 19

Filed 09/01/2006

Page 2 of 3

Dated: September 1, 2006

Respectfully Submitted,

s/ Michael W. Kirk Michael W. Kirk Counsel of Record COOPER & KIRK, PLLC 555 Eleventh Street, NW Suite 750 Washington, DC 20004 (202) 220-9600 (202) 220-9601 (fax)

Of Counsel: Nicholas A. Oldham COOPER & KIRK, PLLC 555 Eleventh Street, N.W. Suite 750 Washington, D.C. 20004 (202) 220-9600 (202) 220-9601 (fax)

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Case 1:06-cv-00141-LAS

Document 19

Filed 09/01/2006

Page 3 of 3

CERTIFICATE OF FILING I certify that on September 1, 2006, the attached document was filed electronically. I understand that service is complete upon filing and that parties may access this filing through the Court's ECF system.

s/ Michael W. Kirk Michael W. Kirk Counsel of Record COOPER & KIRK, PLLC 555 Eleventh Street, NW Suite 750 Washington, DC 20004 (202) 220-9600 (202) 220-9601 (fax)

Of Counsel: Nicholas A. Oldham COOPER & KIRK, PLLC 555 Eleventh Street, N.W. Suite 750 Washington, D.C. 20004 (202) 220-9600 (202) 220-9601 (fax)