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

Case 1:02-cv-00024-FMA

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UNITED STATES COURT OF FEDERAL CLAIMS PUEBLO OF LAGUNA, Plaintiff, v. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) Electronically filed April 1, 2005

No. 02-24L Judge Francis M. Allegra

PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSE TO DEFENDANT'S MOTION PURSUANT TO SECTION 6 OF THE MARCH 19, 2004 RECORD RETENTION ORDER Plaintiff hereby moves pursuant to RCFC 6(b) and 6.1 for an enlargement of time of four days, from April 4, 2005 to and including April 8, 2005, in which to file Plaintiff's Response to Defendant's Motion Pursuant to Section 6 of the March 19, 2004 Record Retention Order. In support of this motion, Plaintiff states as follows: 1. Defendant filed a Motion Pursuant to Section 6 of the March 19, 2004 Record

Retention Order, to amend the Record Retention Order, on March 18, 2005. 2. Defendant filed a motion for leave to file a corrective document (the

declaration of Richard Gregg) in support of its motion on March 21, 2005. 3. The Court granted Defendant's motion for leave to file the declaration of

Richard Gregg on March 22, 2005. 4. Pursuant to RCFC 6(a), 6(e), and 7.1(b), Plaintiff's Response is currently is due

on April 4, 2005. 5. Additional time is needed to prepare the Response because Defendant's

motion to amend includes a Supplemental Status Report with eighteen attachments, in addition

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to the declaration of Richard Gregg, that inform the motion. Plaintiff must review each of these documents thoroughly and address them appropriately before filing its Response. 6. Plaintiff has conferred with Defendant and determined that Defendant does not

oppose this motion. 7. This is the first motion for enlargement of time that Plaintiff has requested.

Respectfully submitted,

/s Alan R. Taradash by /s Donald H. Grove ____________________________ Alan R. Taradash Nordhaus, Haltom, Taylor, Taradash & Bladh, LLP 405 Dr. Martin Luther King Jr. Ave. NE Albuquerque, NM 87102-3541 telephone: 505-243-4275 facsimile: 505-243-4464 Attorney of Record for Plaintiff Of Counsel for Plaintiff: Thomas J. Peckham Daniel I.S.J. Rey-Bear Deidre A. Lujan Nordhaus, Haltom, Taylor, Taradash & Bladh, LLP 405 Dr. Martin Luther King Jr. Ave. NE Albuquerque, NM 87102-3541 Donald H. Grove Nordhaus, Haltom, Taylor, Taradash & Bladh, LLP 1401 K Street NW, Suite 801 Washington, DC 20006 telephone: 202-530-1270 2

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facsimile: 202-530-1920 Dated: April 1, 2005