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

Case 1:04-cv-00786-SGB

Document 37

Filed 05/16/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

) ) ) Plaintiffs, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) ____________________________________)

SACRAMENTO GRAZING ASSOCIATION, INC., et al.,

No. 04-786 L Judge Susan G. Braden

PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSE TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT Under RCFC 6.1, Plaintiffs, Sacramento Grazing Association, James Goss, Frances Goss, Justin Goss, and Brenna Goss, ask this Court for an enlargement of time to file their Response to Defendant's Motion for Summary Judgment. Plaintiffs' Response is due on May 30, 2008. Plaintiffs request thirty-one (31) additional days, or until June 30, 2008, to file their Response. This is Plaintiffs' first request for this purpose. Counsel for Defendant has stated that the Government does not oppose this Motion. This enlargement of time is necessary because of the complexity of the issues presented by this case, as evidenced by the Government's seven exhibits, comprising almost eighty pages of material, in support of their Motion for Summary Judgment. Plaintiffs also seek this enlargement due to other case-related deadlines. Specifically, Plaintiffs' counsel has deadlines in Preservation of Los Olivos v. U.S. Dep't of the Interior, Case No. CV-06-1502 (C.D. Cal.), Klamath Irrigation District v. United States, Case No. 2007-5115 (Fed. Cir.), and discovery matters in Elkins v. District of

Case 1:04-cv-00786-SGB

Document 37

Filed 05/16/2008

Page 2 of 2

Columbia, Case No. 04-0480 (D.D.C). Plaintiffs' counsel has also had three days of depositions in Florida this week and will have an additional day of depositions the week of May 26 in Elmore v. Florida Power & Light Co., Case No. 04-136626(11) (Fla. 17th Cir. Ct.). Because of these scheduling conflicts, Plaintiffs have not had sufficient time to complete their Response by the current deadline. The requested extension will allow Plaintiffs to complete their Response. Plaintiffs therefore respectfully request this Court to enlarge the deadline for the filing of their Response to Defendant's Motion for Summary Judgment by thirty-one (31) days, from May 30, 2008 to June 30, 2008. Respectfully submitted, __s/ Nancie G. Marzulla___ Nancie G. Marzulla Roger J. Marzulla MARZULLA & MARZULLA 1350 Connecticut Avenue Suite 410 Washington, D.C. 20036 (202) 822-6760 (phone) (202) 822-6774 (fax) Dated: May 16, 2008 Counsel for Plaintiffs

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