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

Case 1:02-cv-01894-EJD

Document 70

Filed 12/28/2004

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 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 10 days, until January 13, 2005, within which to file its reply to Defendant United States' ("Defendant") response to Plaintiff's motion for summary judgment on contract liability. Plaintiff's reply currently is due to be filed on January 3, 2005. Defendant filed its response on December 20, 2004. The intervening holidays and schedules of Plaintiff's counsel necessitate this request, and the enlargement of time will allow Plaintiff sufficient time to prepare its reply. This is the first request by Plaintiff regarding the reply. Counsel for Plaintiff has discussed this motion with counsel for Defendant, who indicated that Defendant does not oppose this request. 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 70

Filed 12/28/2004

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: December 28, 2004

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