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

Case 1:98-cv-00419-LB

Document 183

Filed 12/18/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS RESOURCE INVESTMENTS, INC., and LAND RECOVERY, INC., ) ) ) Plaintiffs, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________)

No. 98-419 L Hon. Lawrence J. Block

DEFENDANT'S UNOPPOSED MOTION FOR A FOUR DAY ENLARGEMENT OF TIME IN WHICH TO FILE ITS RESPONSE TO PLAINTIFFS' SECOND SUPPLEMENTAL BRIEF ________________________________________________________________________ Defendant UNITED STATES hereby moves for an enlargement of time of four days, or to and including December 22, 2006, for the filing of the United States' Response to Plaintiffs' Second Supplemental Brief. Defendant's response to Plaintiffs' Second Supplemental Brief is currently due December 18, 2006. No previous enlargements of time for this purpose have been requested. Further, this enlargement will not prejudice Plaintiffs because Defendant will agree to any enlargement Plaintiffs may need in order to file their reply. Counsel for Defendant was out of the country on vacation December 1-8, 2006. Upon her return to the office on December 4, certain unexpected work matters in other pending cases reduced the time available to complete the work on Defendant's brief. In addition, certain medical matters required immediate attention, which also delayed Defendant's efforts to complete the brief. Counsel for Defendant has contacted Counsel for Plaintiffs, who advises that Plaintiffs do not oppose the granting of this enlargement of time.

Case 1:98-cv-00419-LB

Document 183

Filed 12/18/2006

Page 2 of 2

WHEREFORE, Defendant asks that its Motion for a Four Day Enlargement be granted. Dated: December 15, 2006.

Respectfully submitted, SUE ELLEN WOOLDRIDGE Assistant Attorney General Environment & Natural Resources Division

s/ Susan V. Cook by Mark T. Romley SUSAN V. COOK, Sr. Atty MARK T. ROMLEY, Trial Attorney Natural Resources Section Environment & Natural Resources Division Department of Justice P. O. Box 663 Washington, D.C. 20044 Telephone (202) 305-0470 Fax (202) 305-0506 Email: [email protected]