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

Case 1:05-cv-01042-CFL

Document 31

Filed 01/29/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS THE DALLES IRRIGATION DISTRICT, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-1042C (Judge Lettow)

DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests the Court to enlarge the deadline for the submission of the Government's responses to plaintiff's discovery requests by four days, to and including February 2, 2007. The deadline for our responses is January 29, 2007. This is defendant's first motion for this purpose and will not affect any of the Court's other deadlines. Counsel for defendant has contacted counsel for plaintiff regarding this motion who has indicated that he will agree to allow us to deliver to him as much of our response as possible on February 1, 2007, and to serve the remainder on February 2, 2007. Because this approach is both impractical and amounts to an opposition to our request, we believe it necessary to file this motion. This motion is necessary because of an unanticipated delay encountered by undersigned Government counsel in receiving the documents and information necessary to the completion of the Government's responses to plaintiff's interrogatories and document requests. This delay has not allowed undersigned counsel sufficient time to review the information and incorporate it into defendant's responses. The requested enlargement should provide sufficient time to complete and serve our responses to plaintiff's pending discovery requests.

Case 1:05-cv-01042-CFL

Document 31

Filed 01/29/2007

Page 2 of 3

Accordingly, we respectfully request the Court to grant this motion to enlarge the deadline for our responses to plaintiff's discovery requests by four days, to and including February 2, 2007. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director /s/ Gregory T. Jaeger GREGORY T. JAEGER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 (202) 353-7955 January 29, 2007 Attorneys for Defendant

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Case 1:05-cv-01042-CFL

Document 31

Filed 01/29/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on January 29, 2007, a copy of the foregoing "DEFENDANT'S 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/Gregory T. Jaeger