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

Case 1:99-cv-00447-CFL

Document 265

Filed 01/02/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BOSTON EDISON COMPANY Plaintiff, v. THE UNITED STATES, Defendant. ENTERGY NUCLEAR GENERATION CO., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) No. 99-447C ) No. 03-2626C ) (Judge Charles F. Lettow) ) ) ) ) ) ) ) ) ) ) ) )

PLAINTIFF BOSTON EDISON COMPANY'S CONSENT MOTION FOR AN ENLARGEMENT OF TIME Plaintiff Boston Edison Company ("Boston Edison"), pursuant to Rule 6(b) of the Rules of the Court of Federal Claims, respectfully requests an enlargement of time of one day to reply to the United States' response to Boston Edison's Motion for Leave to Take a Rule 30(b)(6) Deposition, which Boston Edison filed on December 1, 2006. The Government filed its response on December 22, 2006. The enlargement that Boston Edison requests would give Boston Edison's reply a due date of January 8, 2007. Boston Edison has made no previous requests for an enlargement of time with respect to this motion. The Government has requested, and been granted, two enlargements of two days each for its response.

DSMDB-2190151v01

Case 1:99-cv-00447-CFL

Document 265

Filed 01/02/2007

Page 2 of 3

Due to the intervening holiday, Boston Edison's counsel was absent during the several days following the filing of the Government's response papers. So that counsel can properly and fully address the issues presented by this motion, counsel respectfully requests one additional day for its reply. Counsel for the Defendant, the United States, has been contacted and has authorized the undersigned counsel to represent that the United States does not oppose this requested enlargement of time for Boston Edison's reply. For the foregoing reasons, Boston Edison respectfully requests that the Court permit it to reply to the United States' response to Boston Edison's Motion for Leave to Take a Rule 30(b)(6) Deposition on January 8, 2007, an enlargement of time of one day.

Date: January 2, 2007

Respectfully submitted, s/ Richard J. Conway____________________ Richard J. Conway DICKSTEIN SHAPIRO LLP 1825 Eye Street NW Washington, D.C. 20006 (202) 420-2200 Counsel of Record for Boston Edison Company

Of Counsel: Nicholas W. Mattia, Jr. Bradley D. Wine Bernard F. Sheehan Lisa M. Barbas DICKSTEIN SHAPIRO LLP 1825 Eye Street NW Washington, D.C. 20006 (202) 420-2200 Neven Rabadjija, Esq. Associate General Counsel NSTAR Electric & Gas Corporation 800 Boylston Street 17th Floor Boston, MA 02199-0228

Case 1:99-cv-00447-CFL

Document 265

Filed 01/02/2007

Page 3 of 3

NOTICE OF ELECTRONIC FILING

I hereby certify that on January 2, 2007, a copy of the foregoing "Plaintiff Boston Edison Company's Consent Motion for an 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/Bradley D. Wine Bradley D. Wine