Free Response to Motion - District Court of Federal Claims - federal

Case 1:01-cv-00570-MCW

Document 147

Filed 02/22/2007

Page 1 of 2

THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ BLUE LAKE FOREST PRODUCTS, INC., ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) __________________________________________) __________________________________________ TIMBER PRODUCTS COMPANY, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant ) __________________________________________) CLR TIMBER HOLDINGS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 01-570C (Judge Williams)

No. 01-627C (Judge Williams)

No. 04-501C (Judge Williams)

PLAINTIFFS' OPPOSITION TO DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME

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Case 1:01-cv-00570-MCW

Document 147

Filed 02/22/2007

Page 2 of 2

Defendant has moved for an enlargement of time of 7 days from February 21, 2007, through and including February 28, 2007, to respond to Plaintiffs' Notice of Subsequent Events. Plaintiffs oppose this motion on the grounds that the Plaintiffs' Notice of Subsequent Events and all of its supporting attachments were filed electronically and served on defendant on February 7, 2007. Thus, as of today February 22, 2007, defendant has already had 15 days within which to respond to Plaintiffs' Notice of Subsequent Events. Further, plaintiffs' counsel was informed by defendant's counsel that he has completed an initial draft of the motion and that all that remains is for him to obtain "comments from the agency" and "submit the response for internal review" before he can finalize the filing of defendant's response (also see page 2 of Defendant's Motion). Accordingly, counsel for plaintiffs told counsel for defendant that plaintiffs have no objection to a short extension of time for this purpose to and including Friday, February 23, 2007.

Plaintiffs' counsel would like to be more accommodating to defendant's counsel's personal situation, but the Plaintiffs' Revised Motion to Compel has been pending in part since 2004. This motion must be resolved in order for the parties to move forward to conclude this case, and plaintiffs simply can not agree to further delay at this juncture.

Respectfully submitted, s/Gary G. Stevens SALTMAN & STEVENS, P.C. 1801 K Street, N.W. Suite M-110 Washington, D.C. 20006 (202) 452-2140 Counsel for Plaintiffs Dated: February 22, 2007 2