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

Case 1:01-cv-00718-ECH

Document 33

Filed 12/21/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) RON AND BETTY BLENDU, et al., ) ) Plaintiffs, ) No. 01-718 L v. ) ) Judge Emily C. Hewitt UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________) JOINT MOTION FOR EXTENSION OF TIME TO FILE STIPULATIONS AND/OR DISPOSITIVE MOTIONS ON TITLE ISSUES Pursuant to the Court's Order of November 7, 2006 (Doc. 28), the parties are due to file a set of title stipulations covering all remaining title issues by December 21, 2006. Alternatively, if the parties are not able to reach a set of title stipulations, Defendant is due to file a dispositive motion on these issues by the same date. The parties report that they have met by phone on a number of occasions regarding title issues. In addition, Defendant has submitted a proposed set of title stipulations to Plaintiffs, which Plaintiffs are in the process of reviewing. Although the parties have not yet reached agreement as to the proposed title stipulations, both parties believe that it is in their best interests to continue their discussions regarding title issues in an effort to reach a set of stipulations. Accordingly, the parties jointly request a 30-day extension of time, to and including January 22, 2007, in which to finalize and file a set of stipulations on title matters. To further facilitate these efforts, the parties also request that the deadline for Defendant to file a dispositive motion on title issues, if needed, be set for February 5, 2007, which is two weeks after the deadline for filing stipulations.

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Case 1:01-cv-00718-ECH

Document 33

Filed 12/21/2006

Page 2 of 2

Dated: December 21, 2006 Respectfully submitted, SUE ELLEN WOOLDRIDGE Assistant Attorney General Environment & Natural Resources Division s/ Lary C. Walker LARY C. WALKER WALKER LAW OFFICE 232 East Main Post Office Box 828 Weiser, ID 83672 TEL: (208) 414-0390 FAX: (208) 414-0404 E-MAIL: [email protected] Attorney for Plaintiffs Attorney for Defendant s/ Kristine S. Tardiff KRISTINE S. TARDIFF United States Department of Justice Environment & Natural Resources Division Natural Resources Section 53 Pleasant Street, 4th Floor Concord, NH 03301 TEL: (603) 230-2583 FAX: (603) 225-1577 E-MAIL: [email protected]

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