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

Case 1:98-cv-00484-JPW

Document 233

Filed 08/18/2005

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) NORTHERN STATES POWER COMPANY, ) ) Plaintiff, ) ) v. ) No. 98-484C ) (Judge Wiese) UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________) DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the Court of Federal Claims, defendant respectfully requests an enlargement of time of six days, to and including August 24, 2005, within which to file its response to plaintiff's Motion For Leave To File Expert Reports Under Seal And Request For Order Regarding Certain Future Damages. Defendant's reply is currently due today, August 18, 2005. This is defendant's first request for an enlargement of time for this purpose. Counsel for plaintiff, Northern States Power Company ("NSP"), has indicated that NSP does not oppose this motion for enlargement of time. The requested enlargement is necessary because other case commitments of Government counsel have made it impossible for counsel to complete the Government's reply brief, obtain review of it, and file it with the Court by the current deadline. The completion of the Government's brief has been delayed, in part, because the attorney assigned responsibility for preparing the Government's brief was out of the office on official travel from August 9 through 12, 2005. For the foregoing reasons, defendant respectfully requests that the Court grant the request for an enlargement of time of six days, to and including August 24, 2005.

Case 1:98-cv-00484-JPW

Document 233

Filed 08/18/2005

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: TODD J. COCHRAN Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Washington, D.C. 20530 s/Heide L. Herrmann HEIDE L. HERRMANN Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington D.C. 20530 Tele: (202) 307-6288 Fax: (202) 307-2503 Attorneys for Defendant

August 18, 2005

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Case 1:98-cv-00484-JPW

Document 233

Filed 08/18/2005

Page 3 of 3

CERTIFICATE OF FILING AND SERVICE I hereby certify that on this 18th day of August, 2005, a copy of foregoing "DEFENDANT'S UNOPPOSED MOTION FOR 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/Heide L. Herrmann