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

Case 1:05-cv-01205-MMS

Document 12

Filed 04/26/2006

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UNITED STATES COURT OF FEDERAL CLAIMS

NELSON CONSTRUCTION COMPANY, an ) Idaho corporation; and DONALD J. NELSON, ) ) ) Plaintiffs, ) ) v. ) The UNITED STATES operating through the ) ) UNITED STATES DEPARTMENT OF ) TRANSPORTATION, FEDERAL ) HIGHWAY ADMINISTRATION, WESTERN FEDERAL LANDS HIGHWAY ) ) DIVISION, Defendant. ______________________________________

Case No. 05-1205C (Judge Margaret M. Sweeney)

PLAINTIFFS' MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S MOTION TO DISMISS Pursuant to Rule 6(b) and 6.1 of the Rules of the United States Court of Federal Claims, Plaintiffs respectfully request an enlargement of time of thirty (30) days, to and including May 27, 2006, within which to respond to defendant's Motion to Dismiss. Our response is currently due on April 27, 2006. This is our first request for an enlargement of time for this purpose. Counsel for defendant has indicated that she does not object to the granting of this motion.

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Case 1:05-cv-01205-MMS

Document 12

Filed 04/26/2006

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Plaintiffs request this enlargement of time because, we are continuing the research and brief the issues presented by defendant's motion, many of which are issues of first impression in this factual context. Accordingly, we respectfully request the Court to enlarge the time to respond to defendant's Motion to Dismiss to and including May 27, 2006. Respectfully submitted this 26th day of April, 2006. TROUT & NEMEC, PLLC

_/s/_________________________________ Kim J. Trout P.O. Box 9695 Boise, Idaho 83707-3695 3067 East Copper Point Dr. Meridian, Idaho 83642 Telephone: (208) 376-4461 Facsimile: (208) 376-4481 Attorneys for Plaintiffs, NELSON CONSTRUCTION COMPANY and DONALD J. NELSON

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