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

Case 1:00-cv-00169-ECH

Document 217

Filed 07/15/2005

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________) THE OSAGE NATION AND/OR TRIBE OF INDIANS OF OKLAHOMA,

Electronically Filed: July 15, 2005 No. 00-169 L Judge Emily C. Hewitt

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO PRODUCE TRANCHE ONE DOCUMENTS TO PLAINTIFF PURSUANT TO THE COURT'S JULY 8, 2005 ORDER Defendant respectfully moves for an enlargement of time to produce documents to Plaintiff pursuant to the Court's July 8, 2005 Order. On July 15, 2005, the parties filed a Joint Stipulation of Confidentiality Regarding Privileged Materials Produced Pursuant to the Court's July 8, 2005 Order and (Proposed) Order to govern the production of the documents to be produced under the July 8, 2005, Order. Defendant seeks an enlargement of time until July 20, 2005, or until the Court enters the Joint Stipulation of Confidentiality and Proposed Order, whichever occurs earlier. Defendant has contacted Plaintiff's counsel regarding this request and Plaintiff's counsel has consented to Defendant's request for this enlargement of time to produce the documents to Plaintiff pursuant to the Court's July 8, 2005 Order. WHEREFORE, Defendant respectfully requests an enlargement of time, to and including July 20, 2005, or until the Court enters the parties' Joint Stipulation and Proposed Order, to produce the documents to Plaintiff pursuant to the Court's July 8, 2005 Order. Respectfully submitted this 15th day of July, 2005, KELLY A. JOHNSON Acting Assistant Attorney General By:

Case 1:00-cv-00169-ECH

Document 217

Filed 07/15/2005

Page 2 of 2

s/ Brett D. Burton BRETT D. BURTON United States Department of Justice Environment and Natural Resources Division P. O. Box 663 Washington, D.C. 20044-0663 Telephone: (202) 305-0212 Fax: (202) 353-2021 Attorney for Defendant OF COUNSEL: Kevin Webb Martin J. LaLonde United States Department of Justice Environment and Natural Resources Division P.O. Box 663 Washington, D.C. 20044-0663 Stephen Simpson Attorney Office of the Solicitor Division of Indian Affairs U.S. Department of the Interior MS 6456 Washington, D.C. 20240 Telephone: (202) 219-1659 Fax: (202) 208-3490 Teresa E. Dawson Senior Counsel Office of Chief Counsel Financial Management Services U.S. Department of the Treasury 401 14th Street, S.W. Room 552A Washington, D.C. 20227 Telephone: (202) 874-2567 Fax: (202) 874-6627 Jason R. Baron Director of Litigation Office of General Counsel National Archives and Records Administration 8601 Adelphi Road Room 3110, NGC College Park, Maryland 20740-6001 Telephone: (301) 837-1499 Fax: (301) 837-0293

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