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

Case 1:99-cv-00550-ECH

Document 307

Filed 06/23/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS THE OSAGE TRIBE OF INDIANS OF OKLAHOMA, Plaintiff, v. : : : : : : : : : : :

No. 99-550 L (into which No. 00-169 L is consolidated) Judge Emily C. Hewitt

THE UNITED STATES OF AMERICA, Defendant.

CONSENT MOTION FOR ENLARGEMENT OF TIME FOR BRADLEY D. BRICKELL TO OPPOSE PLAINTIFF OSAGE NATION'S MOTION TO COMPEL Pursuant to RCFC 6.1, non-party Bradley D. Brickell, Esq., through undersigned counsel, moves this Court for an enlargement of time to respond to Plaintiff Osage Nation's Motion to Compel Bradley D. Brickell With Subpoena Duces Tecum ("Motion to Compel"), and states as follows: 1. Plaintiff served Mr. Brickell with a subpoena on May 29, 2008 seeking certain

documents retained by Mr. Brickell pursuant to attorney retaining lien. ("Subpoena") 2. Subpoena. 3. On June 5, 2008, Plaintiff filed its Motion to Compel production of those By letter dated June 3, 2008, Mr. Brickell set forth his objections to Plaintiff's

documents set forth in the Subpoena. Mr. Brickell's response to Plaintiff's Motion is due on June 23, 2008. 4. On June 11, 2008, the undersigned was retained by Mr. Brickell to respond both

to the Subpoena as well as Plaintiff's Motion to Compel.

Case 1:99-cv-00550-ECH

Document 307

Filed 06/23/2008

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5.

The undersigned counsel and counsel for Plaintiff have conferred on numerous

occasions in an effort to reach an amicable resolution concerning the requested documents, thus obviating the need for this Court's intervention. 6. The undersigned and counsel for Plaintiff are optimistic that their negotiations

will be successful. Mr. Brickell therefore seeks a 14-day enlargement of time, to July 7, 2008, to allow the parties to fully resolve their dispute. In the unlikely event those negotiations fail, Mr. Brickell will respond to the Motion to Compel before July 7. 7. 8. No previous requests for enlargement have been made. Counsel for Plaintiff graciously consented to the relief sought in this motion. Respectfully submitted

Dated: June 23, 2008

/s/ Alan L. Balaran Alan L. Balaran, Esq. Law Office of Alan L. Balaran, PLLC 1111 19th Street, NW Twelfth Floor Washington, DC 20036 (202) 466-5019 [email protected] Counsel for Bradley D. Brickell, Esq.

Case 1:99-cv-00550-ECH

Document 307

Filed 06/23/2008

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CERTIFICATE REGARDING SERVICE I certify that on June 23, 2008, I caused copies of Consent Motion For Enlargement Of Time For Bradley D. Brickell To Oppose Plaintiff Osage Nation's Motion To Compel to be sent via firstclass mail, postage prepaid and via electronic mail to the following: WILSON K. PIPESTEM Pipestem Law Firm, P.C. 1333 New Hampshire Avenue, N.W. Washington, D.C. 20036 [email protected] /s/Alan L. Balaran Alan L. Balaran