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

Case 1:01-cv-00591-FMA

Document 270

Filed 03/06/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) KLAMATH IRRIGATION DISTRICT et al., ) ) Plaintiffs, ) v. ) ) UNITED STATES OF AMERICA, ) No. 01-591 L ) Judge Francis M. Allegra Defendant, ) ) PACIFIC COAST FEDERATION OF ) FISHERMEN'S ASSOCIATIONS, ) ) Defendant-Intervenor. ) PLAINTIFFS' UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to RCFC 6(b) and 6.1, Plaintiffs move for a 30-day extension of time, to and including April 19, 2006, in which to file their opposition to Defendant's Motion for Summary Judgment. Defendant's counsel has indicated that Defendant does not oppose the granting of this motion; Plaintiffs were unable to reach Defendant-Intervenor's counsel. This is the first such enlargement Plaintiffs have sought. Plaintiffs seek an enlargement of time in which to file their response to allow Plaintiffs' counsel sufficient time to prepare Plaintiffs' opposition to Defendant's motion. Plaintiffs counsel are currently involved in several cases before this and other courts that have pressing deadlines that coincide with the scheduled deadline for filing Plaintiffs' opposition in this case. Moreover, Plaintiffs' counsel have a number of cases that will require travel in the upcoming weeks. Some of this travel was scheduled early on in anticipation of Defendant filing its motion for summary judgment on January 20, 2006, as originally scheduled by the Court. Additionally, Plaintiffs must respond not only to the brief of Defendant, but also that of amicus National Resources Defense Council. In short, Plaintiffs need an enlargement of time in order to allow for

Case 1:01-cv-00591-FMA

Document 270

Filed 03/06/2006

Page 2 of 2

the filing of a brief that fully addresses Defendant's and amicus' arguments, given Plaintiffs' counsel's schedule. For the foregoing reasons, Plaintiffs request that this Court grant their unopposed motion for an enlargement of time. Respectfully submitted,

s/ Nancie G. Marzulla Nancie G. Marzulla Roger J. Marzulla MARZULLA & MARZULLA 1350 Connecticut Ave., N.W. Suite 410 Washington, D.C. 20036 202-822-6760 202-822-6774 (fax) Dated: March 6, 2006

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