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

Case 1:00-cv-00697-JFM

Document 296

Filed 03/01/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

WISCONSIN ELECTRIC POWER COMPANY, Plaintiff, v. THE UNITED STATES, Defendant.

No. 00-697C Senior Judge Merow

PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b), plaintiff, Wisconsin Electric Power Company ("WE"), respectfully requests an enlargement of time of four days from March 5, 2007 until March 9, 2007 within which to serve WE's Opposition to the Government's Motion for Partial Summary Judgment Regarding Plaintiff's Claim for Prejudgment Interest ("WE's Opposition"). This is WE's first request for an enlargement of time for service of its response. Counsel for the Government has authorized us to state that the Government does not oppose WE's request for an enlargement of time. WE and its counsel have devoted considerable time the past few weeks in responding to four other Government motions in this litigation and in other pretrial activities. The requested enlargement will permit WE counsel sufficient time to complete a draft of WE's Opposition and to review this draft Opposition with WE prior to filing of this pleading. For the foregoing reasons, we respectfully request that the Court grant this motion and extend the time for WE to respond to the Government's motion for partial summary judgment by four days until March 9, 2007.

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Case 1:00-cv-00697-JFM

Document 296

Filed 03/01/2007

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Dated: March 1, 2007

Of Counsel: Donald J. Carney Perkins Coie LLP 607 Fourteenth St., NW Washington, D.C. 20005 Tel.: 202-434-1675 Fax: 202-434-1690 [email protected]

s/Richard W. Oehler by s/ Emily C.C. Poulin Richard W. Oehler Perkins Coie LLP 1201 Third Avenue, 40th Floor Seattle, Washington 98101-3099 Tel.: 206-583-8419 Fax: 206-583-8500 [email protected] Attorney of Record for Plaintiff Wisconsin Electric Power Company

[28795-0001/13063289_1.DOC]

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Case 1:00-cv-00697-JFM

Document 296

Filed 03/01/2007

Page 3 of 3

CERTIFICATE OF SERVICE I certify under penalty of perjury that, on March 1, 2007, I caused a copy of the foregoing "Plaintiff's Unopposed Motion for an Enlargement of Time" to be 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/Emily C.C. Poulin Emily C.C. Poulin

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