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


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Case 1:99-cv-00447-CFL

Document 239

Filed 11/23/2005

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BOSTON EDISON COMPANY, Plaintiff, v. UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 99-447C No. 03-2626C (Judge Lettow)

ENTERGY NUCLEAR GENERATION CO., Plaintiff, v. UNITED STATES OF AMERICA, Defendant.

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant respectfully requests a two-day enlargement of time, to and including December 2, 2005, to submit the Joint Status Report ("JSR") in these cases. The JSR is currently due on November 30, 2005. This is defendant's first request for an enlargement of time for this purpose. Counsel for the plaintiffs have stated that our request will not be opposed. Although the parties have had preliminary discussions concerning scheduling issues, an enlargement of time is necessary because of the Thanksgiving holiday and the fact that counsel for both the defendant and plaintiff, Boston Edison Company, will be out of the office on workrelated travel through November 30, 2005. An enlargement of time of two days, to and

Case 1:99-cv-00447-CFL

Document 239

Filed 11/23/2005

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including, December 2, 2005, will permit the parties sufficient time to continue their discussions regarding scheduling issues and provide the Court with a JSR. For the foregoing reasons, defendant respectfully requests that the Court grant this unopposed motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

DAVID M. COHEN Director OF COUNSEL: JANE K. TAYLOR Office of General Counsel U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585 JOSHUA E. GARDNER Civil Division Department of Justice 1100 L Street, NW Washington, D.C. 20530 s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director s/ Alan J. Lo Re by Joshua E. Gardner ALAN J. LO RE Senior Trial Counsel U.S. Department of Justice Civil Division Commercial Litigation Branch 1100 L Street, N.W. ATTN: Classification Unit, 8th Floor Washington, D.C. 20530 Tel: 202-307-0226 Fax: 202-307-2503

November 23, 2005

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Case 1:99-cv-00447-CFL

Document 239

Filed 11/23/2005

Page 3 of 3

CERTIFICATE OF FILING, AND CERTIFICATE OF SERVICE I hereby certify that on this 23rd day of November, 2005, a copy of foregoing "UNOPPOSED 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/Joshua E. Gardner