Case 1:02-cv-01795-JFM
Document 114
Filed 01/25/2006
Page 1 of 3
IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) THE SWEETWATER, A WILDERNESS ) LODGE LLC, ) ) Plaintiff, ) ) No. 02-1795C v. ) (Senior Judge Merow) ) THE UNITED STATES, ) ) Defendant. ) ____________________________________) DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant, the United States, respectfully requests an enlargement of time of one business day, to and including January 30, 2006, within which the parties are to file their respective responses to each other's post-trial brief and proposed findings of fact. The parties' post-trial briefs and proposed findings of fact are currently due on January 27, 2006. This is our first request for an enlargement of time to file and serve our responses to plaintiff's post-trial brief and proposed findings of fact. Plaintiff's counsel has stated that plaintiff does not oppose this request. The requested enlargement is necessary to permit us to complete the preparation of our responses to plaintiff's 52-page post-trial brief and 233 proposed findings of fact, which include hundreds of citations to the nearly 3,000 page trial transcript. The additional time will permit the undersigned trial attorney to complete his consultations with agency counsel and supervisory lawyers at the Department of Justice, and prepare thorough responses that will be of greatest assistance to the Court. For the foregoing reasons, we respectfully request that the Court grant our motion for an enlargement of time of one business day, to and including January 30, 2006, for the
Case 1:02-cv-01795-JFM
Document 114
Filed 01/25/2006
Page 2 of 3
parties to file their respective responses to each other's post-trial brief and proposed findings of fact.
Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director
s/ John H. Williamson JOHN H. WILLIAMSON Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice ATTN: Classification Unit 1100 L St. N.W., 8th floor Washington, D.C. 20530 Tel: (202) 307-0277 Fax: (202) 307-0972 January 25, 2006 Attorneys for Defendant
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Case 1:02-cv-01795-JFM
Document 114
Filed 01/25/2006
Page 3 of 3
CERTIFICATE OF SERVICE I certify under penalty of perjury that on this 25th day of January, 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.
s/ John H. Williamson