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

Case 1:04-cv-00786-SGB

Document 32

Filed 03/13/2008

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

DEFENDANT'S UNOPPOSED MOTION FOR AN EXTENSION OF TIME TO FILES ITS MOTION FOR SUMMARY JUDGMENT Defendant United States hereby moves for a 30-day extension of time to file its motion for summary judgment, to and including April 30, 2008. In support thereof, Defendant states as follows. Pursuant to the parties' Joint Status Report of January 11, 2008 (Doc. 30), and the Court's subsequent Scheduling Order of January 14, 2008 (Doc. 31), Defendant is due to file its motion for summary judgment on or before March 31, 2008. Defendant is requesting a 30-day extension of time due to other case-related deadlines. In particular, Defendant's counsel of record is involved in an expedited briefing schedule on certain discovery matters in Kingman Reef Atoll Investments, LLC v. United States, No. 06-828L (Fed. Cl.), which include a motion for a protective order filed on March 11, a reply brief that is due on March 27, and a conference with the Court on April 10. In addition, Defendant's counsel of record is preparing for an oral argument in Central Pines Land Co. v. United States, No. 98-314L (Fed. Cl.), scheduled for March 27, 2008, and expects to be out of the office for depositions in another matter in early April. Finally, the 30-day extension of time requested by Defendant will 1

Case 1:04-cv-00786-SGB

Document 32

Filed 03/13/2008

Page 2 of 2

allow DOJ attorney Kathleen Doster, who is due to return from maternity leave in mid-April, to participate in this briefing.1 Defendant has contacted Plaintiffs' counsel regarding this request for an extension of time, and Plaintiffs' counsel has indicated that the Plaintiffs do not oppose the motion. WHEREFORE, Defendant respectfully requests a 30-day extension of time to file its motion for summary judgment, to and including April 30, 2008.

Dated: March 13, 2008 Respectfully submitted, RONALD J. TENPAS Assistant Attorney General Environment & Natural Resources Division

s/Kristine S. Tardiff KRISTINE S. TARDIFF United States Department of Justice Environment & Natural Resources Division 53 Pleasant Street, 4th Floor Concord, NH 03301 TEL: (603) 230-2583 FAX:(603) 225-1577 [email protected] Attorney of Record for Defendant

Ms. Doster served as counsel of record for Defendant in this case from June 2004 through August 2007, and is expected to resume her participation upon returning to the office. 2

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