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

Case 1:05-cv-00367-ECH

Document 21

Filed 03/15/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS No. 05-367 L into which have been consolidated Nos. 05-484 L, 05-537 L, 05-1082 L, 05-1083 L, 05-1173 L, and 05-1175 L ) ) ) ) ) ) ) ) )

GERALD E. ROTH, et. al., Plaintiffs, v. THE UNITED STATES OF AMERICA, Defendant. _________________________________________

Honorable Emily C. Hewitt

JOINT MOTION FOR AN ENLARGEMENT OF TIME IN WHICH TO PROVIDE OWNERSHIP DOCUMENTS AND TO FILE DEFENDANT'S MOTION TO DISMISS The parties, through counsel, hereby move pursuant to RCFC 6(b) for an enlargement of time for plaintiffs to provide ownership documents to defendant and defendant to file its motion to dismiss. Pursuant to the Court's order filed February 28, 2006, counsel for plaintiffs is in the process of gathering relevant ownership documents and can provide these documents to defendant by Tuesday, March 28, 2006. As these documents relate to defendant's motion, defendant requires time to review the documents after their receipt. Accordingly, the parties respectfully request the following schedule: Tuesday, March 28, 2006 Deadline for plaintiffs to provide relevant ownership documents Deadline for defendant to file its motion to dismiss

Tuesday, April 4, 2006

Case 1:05-cv-00367-ECH

Document 21

Filed 03/15/2006

Page 2 of 2

This joint motion was jointly prepared by counsel for plaintiffs and counsel for defendant. Plaintiffs' counsel of record has authorized the undersigned counsel for the defendant to sign and file this motion on behalf of both parties. Dated: March 15, 2006 Respectfully submitted, SUE ELLEN WOOLDRIDGE Assistant Attorney General Environment & Natural Resources Division

s/ Glade L. Hall by s/ Kelle S. Acock _________________________ Glade L. Hall 105 Mt. Rose St. Reno, Nevada 89509 Attorney of Record for Plaintiffs

s/ Kelle S. Acock _________________________ Kelle S. Acock Natural Resources Section Environment & Natural Resources Division Department of Justice P.O. Box 663 Washington, D.C. 20044-0663 Tel: 202-305-0428 Fax: 202-305-0506 Email: [email protected] Attorney of Record for Defendant

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