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

Case 1:02-cv-01894-EJD

Document 80

Filed 03/21/2005

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS CONSUMERS ENERGY COMPANY, Plaintiff, v. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) ) )

COFC No. 02-1894-C (Chief Judge Damich)

PLAINTIFF CONSUMER ENERGY COMPANY'S THIRD UNOPPOSED MOTION FOR ENLARGMENT OF TIME Pursuant to Court of Federal Claims Rule 6(b)(1), Plaintiff Consumers Energy Company ("Plaintiff"), by and through counsel, hereby respectfully requests an enlargement of 31 days, until April 21, 2005, within which to file its proposed motions for summary judgment on the rate and date of acceptance of spent nuclear fuel. Such motions currently are due to be filed on March 21, 2005. Plaintiff seeks additional time within which to file its summary judgment motions based on ongoing settlement discussions with Defendant the United States. Counsel for Plaintiff has discussed this motion with counsel for Defendant, who indicated that Defendant does not oppose this request. This is the third request for additional filed by Plaintiff with respect to the motions for summary judgment on rate and date of acceptance. Respectfully submitted, ____/s/ Thomas O. Mason__________ Thomas O. Mason WILLIAMS MULLEN 8270 Greensboro Drive, Suite 700 McLean, VA 22102 (703) 760-5200 (phone) (703) 748-0244 (facsimile) Attorneys for Plaintiff Consumers Energy Company

Case 1:02-cv-01894-EJD

Document 80

Filed 03/21/2005

Page 2 of 2

OF COUNSEL: Harvey J. Messing (P23309) Jeffrey S. Theuer (P44161) LOOMIS, EWERT, PARSLEY, DAVIS & GOTTING, P.C. 232 S. Capitol Avenue, Suite 1000 Lansing, MI 48933 (517) 482-2400 James E. Brunner (P28051) Arunas T. Udrys (P21660) Consumers Energy Company 212 West Michigan Avenue Jackson, MI 49201 (517) 788-2151 Dated: March 21, 2005

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