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

Case 1:02-cv-01795-JFM

Document 131

Filed 09/20/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

THE SWEETWATER, A WILDERNESS LODGE LLC, Plaintiff, v. THE UNITED STATES, Defendant.

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No. 02-1795C (Senior Judge Merow)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 10 days, to and including October 5, 2006, within which to file its response to plaintiff's motion for reconsideration. Defendant's response is currently due to be filed on or before September 25, 2006. This is defendant's first request for an enlargement of time. Counsel for plaintiff has represented that plaintiff does not oppose this request. Additional time is necessary to adequately respond to the points raised in plaintiff's motion for reconsideration. Following the departure of the attorney originally assigned to represent the United States in this litigation, the case (following a trial and pending a decision by the Court) was transferred to the undersigned counsel. Counsel needs additional time to review the voluminous case record, read the trial transcript and briefing that led to the Court's decision, and confer with agency counsel. Agency counsel was on vacation the week of September 11, 2006. Moreover, the undersigned will be out of the office from September 18 through September 22 to take depositions in an unrelated case in California and Colorado.

Case 1:02-cv-01795-JFM

Document 131

Filed 09/20/2006

Page 2 of 2

For these reasons, defendant respectfully requests that the Court grant its unopposed motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director OF COUNSEL: KENNETH S. CAPPS Office of General Counsel U.S. Department of Agriculture 740 Simms Street, Room 309 Golden, CO 80401-4720 s/ Gregg M. Schwind GREGG M. SCHWIND Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington D.C. 20530 Tel: (202) 353-2345 Fax: (202) 514-8624 Attorneys for Defendant September 20, 2006

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