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

Case 1:98-cv-00126-JFM

Document 788

Filed 04/16/2004

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS : : : Plaintiff, : : v. : : UNITED STATES OF AMERICA, : : Defendant. : __________________________________________: YANKEE ATOMIC ELECTRIC COMPANY, __________________________________________

No. 98-126 C (Senior Judge Merow)

CONSENT MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, Yankee Atomic Electric Company hereby requests an enlargement of time to file its Opposition to Defendant's Motion In Limine to Exclude Testimony and Evidence Regarding Plaintiff's Request for Pre-Breach Damages. Yankee Atomic's Opposition is currently due today, Friday, April 16, 2004. Yankee Atomic seeks an enlargement of time of 5 business days to file its Opposition on Friday, April 23, 2004. The time for this Opposition to be filed was previously enlarged once, from February 27, 2004 until today. Oppositions to several motions filed by the government were due to be filed today; the Opposition that is the subject of this motion is the only one due today that is not being filed. As grounds for this further enlargement, Yankee Atomic submits that one of the attorneys responsible for preparing this Opposition had a medical emergency in his family last week that delayed work on the Opposition and has precluded Yankee Atomic from being able to complete the Opposition in time for filing today. Yankee Atomic needs this enlargement to have adequate

Case 1:98-cv-00126-JFM

Document 788

Filed 04/16/2004

Page 2 of 2

time and opportunity to fully respond to the Defendant's Motion. Counsel for the government has consented to this Motion. For the foregoing reasons, Yankee Atomic respectfully requests the Court to grant its Motion for Enlargement of Time through April 23, 2004 in which to file its Opposition.

Respectfully submitted s/ Jerry Stouck________ JERRY STOUCK Spriggs & Hollingsworth 1350 I Street, N.W., Ninth Floor Washington, D.C. 20005 Tel. (202) 898-5800 Fax (202) 682-1639 Counsel for Plaintiff, YANKEE ATOMIC ELECTRIC COMPANY Of Counsel: Robert L. Shapiro Peter J. Skalaban, Jr. SPRIGGS & HOLLINGSWORTH

Date: April 16, 2004