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

Case 1:05-cv-00186-FMA

Document 18

Filed 03/10/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________) LAVETTA ELK,

05-186L Judge Francis M. Allegra

JOINT MOTION FOR AN EXTENSION OF TIME Pursuant to RCFC 6.1, Counsel for Defendant and Counsel for Plaintiff move for a fourteen (14) day enlargement of time from March 17, 2006 to and including March 31, 2006 in which to file a Joint Status Report. This is the parties first request for an enlargement of time to meet this deadline. The Court's Order of January 20, 2006 required Defendant to file an Answer on February 17, 2006 and the parties to file a Joint Status Report on March 17, 2006. Because Counsel for Defendant is scheduled to attend training at the National Advocacy Center, in Columbia, South Carolina from March 13, 2006 through March 17, 2006, the logistics of coordinating the Joint Status Report are problematic. Defendant's Counsel is also in need of the additional fourteen days to coordinate with Plaintiff's Counsel regarding the filing of the Joint Status Report, because of unanticipated demands places on a particularly heavy personal docket. During the week of February 28, 2006, Defendant's Counsel filed a brief in Western Shoshone National Council v. United States, 04-702 (D. Nev.). During the week of March 6, 2006, Defendant's Counsel filed a motion to dismiss in Yowell v. United States, 05-634 (D. Nev.) and a pleading in Simmons v. United States, 04-1759 (Fed. Cl.). In addition, Counsel for Plaintiff is presently out 1

Case 1:05-cv-00186-FMA

Document 18

Filed 03/10/2006

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of the state completing depositions in Texas. Accordingly, the parties require an additional fourteen days, in order to complete their Joint Status Report. A proposed order is attached. Counsel for Plaintiff consents to the filing of this Joint Motion. Respectfully submitted this 10th day of March, 2006,

SUE ELLEN WOOLDRIDGE Assistant Attorney General Environment and Natural Resources Division United States Department of Justice

/s/ Sara E. Culley SARA E. CULLEY (K.S. Bar No. 20898) Trial Attorney United States Department of Justice Natural Resources Section P.O. Box 663 Washington, D.C. 20044-0663 Tel: (202) 305-0466 Facsimile: (202) 305-0267 OF COUNSEL: Sharon Pudwill, Esq. Office of the Field Solicitor United States Department of the Interior Patrick Butler, CPT, JA. General Litigation Branch United States Army Litigation Division

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