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

Case 1:00-cv-00169-ECH

Document 198

Filed 05/11/2005

Page 1 of 2

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

Electronically Filed May 11, 2005 No. 00-169 L Judge Emily C. Hewitt

THE OSAGE NATION'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO REPLY TO DEFENDANT'S OPPOSITION TO THE OSAGE NATION'S OBJECTIONS TO DEFENDANT'S PRIVILEGE CLAIMS The Osage Nation respectfully moves for a seven-day enlargement of time, to and including May 20, 2005, to reply to Defendant's Opposition to the Osage Nation's Objections to Defendant's Privilege Claims. In support of this motion, the Osage Nation states the following: 1. The Osage Nation has not previously requested an extension of the schedule

established by the Court's April 15, 2005 Order. 2. Under Paragraph 1(a) of the Court's April 15, 2005 Order, Defendant was given

thirty-six (36) days to prepare and file its Opposition to the Osage Nation's Objections to Defendant's Privilege Claims. In addition, Defendant's Opposition, filed on May 6, 2005, consists of a brief that is thirty-three (33) pages in length and supplemented by an appendix that is fortytwo (42) pages in length. 3. One document contained in the Appendix to Defendant's Opposition to the Osage

Nation's Objections to Defendant's Privilege Claims is a thirty-two (32) page "Final Privilege Log" that contains document information and descriptions not previously provided to the Osage Nation in earlier drafts of Defendant's privilege logs.

Case 1:00-cv-00169-ECH

Document 198

Filed 05/11/2005

Page 2 of 2

4.

After an initial review of Defendant's "Final Privilege Log" and the revised

document descriptions contained therein, the Osage Nation believes that, if given additional time to consider this new information, it may be able to, with respect to some documents, withdraw its objections to Defendant's privilege assertions and, thereby, eliminate the need for an in camera review of any such documents. 5. Under Paragraph 1(a) of the Court's April 15, 2005 Order, the Osage Nation

currently has been given only seven days within which to file its reply to Defendant's Opposition to the Osage Nation's Objections to Defendant's Privilege Claims. 6. The Osage Nation has conferred with counsel of record for Defendant regarding

this motion and Defendant has consented to the Osage Nation's motion for a seven-day enlargement of time, to and including May 20, 2005, to reply to Defendant's Opposition to the Osage Nation's Objections to Defendant's Privilege Claims.

Dated this May 11th, 2005

Respectfully submitted,

s/Wilson K. Pipestem WILSON K. PIPESTEM Pipestem Law Firm, P.C. 1333 New Hampshire Avenue, N.W. Washington, D.C. 20036 Telephone: (202) 419-3526 Fax: (202) 659-4931 [email protected] Attorney for Plaintiff Osage Nation

2