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

Case 1:98-cv-00897-FMA

Document 154

Filed 04/19/2005

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ROBERT BRACE, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) __________________________________________)

Case No. 98-897 L Hon. Francis M. Allegra

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME OF TWO BUSINESS DAYS IN WHICH TO FILE POST-TRIAL BRIEF _________________________________________ Defendant hereby respectfully moves for an enlargement of time of two days, or to and including Thursday, April 21, 2005, in which to file its Post-trial Brief Defendant's Post-trial Brief is due Tuesday, April 19, 2005. No previous enlargement of time has been sought by defendant for filing the Post-trial Brief. This motion for an enlargement of time is filed for good cause. Counsel of record, Susan V. Cook, has been appointed acting Assistant Chief in the General Litigation Section beginning Monday, April 25, 2005. In anticipation of this transition, unexpected and time-consuming issues have arisen recently that have impacted her ability to assist in completing the Pre-trial Brief by the filing date. Counsel for defendant has contacted counsel for plaintiff, who advises that he 1

Case 1:98-cv-00897-FMA

Document 154

Filed 04/19/2005

Page 2 of 2

has no objection to the granting of this motion for enlargement of time. Dated: April 19, 2005. Respectfully submitted, KELLY JOHNSON Acting Assistant Attorney General Environment & Natural Resources Division

s/ Susan V. Cook by s/ Sydney F. Cook SUSAN V. COOK, Senior Attorney General Litigation Section Environment & Natural Resource Division United States Department of Justice Post Office Box 663 Washington, D.C. 20044-0663 202-305-0470; FAX: 202-514-8164 Email: [email protected] Attorney for Defendant

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