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

Case 1:04-cv-00786-SGB

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Filed 06/30/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

Sacramento Grazing Association, Inc., et
al. ,

No. 04-786
Plaintiff,
v.
Judge Susan G. Braden

United States,

Defendants.
Plaintiffs Second Unopposed Motion for Enlaraement of Time to
File Response to Defendant's Motion for Summary Judament
Under RCFC 6.1, Plaintiffs, Sacramento Grazing Association, Inc. James Goss,

Frances Goss, Justin Goss, and Brenna Goss (collectively "Plaintiffs"), herby request a

second enlargement of time to file their Response to Defendant's Motion for Summary

Judgment. Plaintiffs were previously granted a thirty-one (31) day extension of time,
and the Response is currently due on June 30, 2008. See May 19, 2009 Court Order. Plaintiffs' requests an additional 45 days, up to and including August 15, 2008 to file a

Response.
The undersigned had formerly represented the Plaintiffs in this matter. See April

9,2007 Order Granting Motion to Substitute Attorney. A Motion for Leave to Change
Attorney of Record was filed on June 27,2008 to reinitiate my representation of
Plaintiffs in this matter. During the time that Nancie Marzulla of the Marzulla Law Firm
represented the Plaintiffs, discovery has been conducted and the Defendant has filed a
Motion for Summary Judgment, including approximately eighty pages of exhibits.

Although arrangements have been made, the Plaintiffs' files in this case have not yet

Case 1:04-cv-00786-SGB

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been forwarded by the Marzulla Law Firm, and there has been no opportunity to review

the files and adequately prepare a Response to Defendant's Motion for Summary

Judgment. Therefore, Plaintiffs' requests an additional 45 days, up to and including
August 15, 2008 to file a Response to Defendant's Motion for Summary Judgment.
Kathleen Doster, attorney for the United States in this matter, has indicated that she is not opposed to this request for an extension of time.

Dated:June 1. Î ,2008
Michael J. V n
HANSON BRIDG 425 Market Street, 26th Floor San Francisco, CA 94105 Telephone: (415) 777-3200

Facsimile: (415) 995-3566
Attorneys for Plaintiff Sacramento Grazing Association

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CERTIFICATE OF SERVICE
I hereby certify that on this 30th day of June, 2008, a true and accurate copy of

the Plaintiffs Motion for Leave to Change Plaintiffs' Attorney of record was served upon
counsel by first-class mail, by placing the same in the United States mail, postage
prepaid, addressed to:

Kathleen Lennon Doster
U.S. Department of Justice Environment & Natural Resources Division P.O. Box 663 Washington, DC 20044-663

Tel: (202) 305-0481 Fax: (202) 305-0506
Kath leen .doster(ãusdoi. qov

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