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

Case 1:98-cv-00726-EJD

Document 167

Filed 06/13/2005

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ______________________________________________________________________________

GRASS VALLEY TERRACE, a California Limited Partnership, et al.,
Plaintiffs, File Nos. 98-726C; 98-726-2C through 98-726-14C; 04-1299C & 04-1317C Chief Judge Edward J. Damich

v. THE UNITED STATES Defendant. ______________________________________________________________________________ PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the Court of Federal Claims, plaintiffs respectfully request an enlargement of time, up to and including June 20, 2005, for the purpose of filing their Reply in Support of Plaintiff's Motion for Substitution of Plaintiff in Case No. 98-7263C and their Reply in Support of Plaintiff's Motion for Substitution of Plaintiff in Case No. 98-7264C. Plaintiffs understand that their replies are currently due on June 13, 2005 for Case No. 98-7263C and June 16, 2005 for Case No. 98-7264C. (The electronic filing system, however, indicates that plaintiffs' replies are due on June 16, 2005 and June 20, 2005, respectively.) This is plaintiffs' first request for an enlargement of time for this purpose. Plaintiffs have informed counsel for the United States of their intention to seek this enlargement of time and the United States does not object to, nor intend to oppose, this motion. Counsel for plaintiffs are working to prepare the two reply briefs at issue, but other pressing matters in numerous related cases have prevented counsel from being able to dedicate a sufficient amount of time to prepare their replies by the current due date. Most significantly, as the Court is aware, the parties are currently engaged in settlement discussions in this case. At the

Case 1:98-cv-00726-EJD

Document 167

Filed 06/13/2005

Page 2 of 2

same time, plaintiffs are engaged in preparation for the additional discovery and possible trial of this matter should the parties' efforts to resolve this case short of trial fail. In addition, by requesting this extension, plaintiffs seek to clarify any confusion brought on by the apparent conflict between the due dates stated in the Court's electronic filing system and the dates that plaintiffs believe their replies are due under Rule 7.2(b). Accordingly, plaintiffs respectfully request that the Court grant this Unopposed Motion for Enlargement of Time for good cause shown and (1) extend the current deadline for filing their Reply in Support of Plaintiff's Motion for Substitution of Plaintiff in Case No. 98-7263C by seven days and (2) extend the current deadline for filing their Reply in Support of Plaintiff's Motion for Substitution of Plaintiff in Case No. 98-7264C by four days, resulting in a due date of June 20, 2005 for both filings.

Dated: June 13, 2005 Filed Electronically

s/Jeff H. Eckland Jeff H. Eckland Mark J. Blando, Of Counsel ECKLAND & BLANDO LLP 700 Lumber Exchange 10 South Fifth Street Minneapolis, MN 55402 Tele: 612-305-4444 Fax: 612-305-4439