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

Case 1:05-cv-01042-CFL

Document 16

Filed 04/28/2006

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 its reply to the response filed by plaintiff, the Dalles Irrigation District, to defendant's motion to dismiss. Defendant requests that the current deadline for its reply (i.e., May 1, 2006) be enlarged by two days, to and including May 3, 2006. This is defendant's third motion for this purpose.1 Counsel for defendant has unsuccessfully attempted to contact counsel for plaintiff regarding this motion and is, therefore, unable to state whether plaintiff opposes this motion. This motion is necessary because of undersigned counsel's assignment, upon an emergency basis late in the day on April 27, 2006, to assist with a bid protest matter involving injunctive relief before Judge Wheeler of this Court.

Defendant's first and second motions, also unopposed, requested 31 days and 14 days respectively.

1

Case 1:05-cv-01042-CFL

Document 16

Filed 04/28/2006

Page 2 of 3

Chapman Law Firm v. United States. This emergency assignment will require undersigned counsel to attend a hearing scheduled for April 28, 2006 and, perhaps, to engage in other efforts as well. As a result, undersigned counsel will be unable to complete defendant's reply by the current deadline. Accordingly, we respectfully request the Court to grant this motion to enlarge the deadline for our reply by two days, to and including May 3, 2006. 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 April 28, 2006 -2Attorneys for Defendant

Case 1:05-cv-01042-CFL

Document 16

Filed 04/28/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on April 28, 2006, 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