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

Case 1:99-cv-00447-CFL

Document 226

Filed 04/15/2005

Page 1 of 3

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

No. 99-447C (Judge Lettow)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, respectfully requests that the Court grant defendant an enlargement of one additional business day, to and including April 18, 2005, to respond to plaintiff's written discovery requests. Pursuant to the Court's recent order, those responses are currently due to be served by April 15, 2005. Counsel for plaintiff has represented that plaintiff, Boston Edison Company ("Boston"), does not oppose this motion. In preparing our responses to these written discovery requests, we have been informed that some of the information at issue is confidential. However, agency counsel who normally assists us in evaluating the appropriateness of disclosure of particular information has been out of the office this week, and, after evaluating our proposed responses, we have determined that we need her input upon some of these issues before we serve our responses to the written discovery requests. She is scheduled to return to the office on Monday, April 18, 2005, and we believe that we can resolve questions about this information at that time. Accordingly, we respectfully request that the Court grant us an additional business day to respond to the plaintiff's written discovery requests. For the foregoing reasons, we respectfully request that the Court grant this motion for an enlargement of time.

Case 1:99-cv-00447-CFL

Document 226

Filed 04/15/2005

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director OF COUNSEL: JANE K. TAYLOR Office of General Counsel U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585 s/ Alan J. Lo Re 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) 514-7300 Fax: (202) 307-2503 Attorneys for Defendant

April 15, 2005

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Case 1:99-cv-00447-CFL

Document 226

Filed 04/15/2005

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that, on April 15, 2005, a copy of the foregoing "DEFENDANT'S 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/ Harold D. Lester, Jr.