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

Case 1:07-cv-00693-NBF

Document 8

Filed 11/20/2007

Page 1 of 2

UNITED STATES COURT OF FEDERAL CLAIMS ) DOROTHY L. BIERY et. al., ) ) Plaintiffs, ) v. ) ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) _________________________________________ )

No. 07-693 L

Honorable Nancy B. Firestone

THE UNITED STATES' UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME IN WHICH TO FILE ANSWER Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, Defendant, the United States of America, hereby moves for an enlargement of time of three (3) weeks, up to and including December 17, 2007, in which to file an Answer to Plaintiffs' Complaint. The Answer is currently due on November 26, 2007. This is the United States' first request for an enlargement of time. This enlargement of time is necessary, in part, because there has a been a change in the United States' attorney of record from G. Evan Pritchard to William Shapiro. In addition, the enlargement of time is necessary given existing travel plans associated with the upcoming Thanksgiving holiday. This additional time will allow the undersigned counsel to coordinate with agency counsel and prepare the Answer. Counsel for the United States has conferred with counsel for Plaintiffs, and counsel for Plaintiffs has indicated that Plaintiffs are not opposed to this motion for an extension of time. Accordingly, the United States respectfully requests the Court grant this motion, and permit the United States to file an Answer to Plaintiffs' Complaint on or before December 17, 1

Case 1:07-cv-00693-NBF

Document 8

Filed 11/20/2007

Page 2 of 2

2007. Respectfully submitted: November 20, 2007 RONALD J. TENPAS Acting Assistant Attorney General Environment & Natural Resources Division

_/s William J. Shapiro_______________ WILLIAM SHAPIRO Natural Resources Section Environment & Natural Resources Division Department of Justice 501 - I Street, Suite 9-700 Sacramento, CA 95814-2322 Phone: 916-930-2207 Fax: 916-930-2210 Email: [email protected] Attorney of Record for Defendant

2