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

Case 1:98-cv-00726-EJD

Document 158

Filed 04/08/2005

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. ______________________________________________________________________________ PLAINTIFF'S 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 of four days, up to and including April 15, 2005, for the purpose of filing plaintiffs' Opposition to Defendant's Motion to Dismiss. Plaintiff's response is

currently due on April 11, 2005. 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 have worked diligently to prepare Plaintiff's Opposition to Defendant's Motion to Dismiss in Nos. 98-7265C and 98-72613C. However, other pressing matters have prevented counsel from being able to dedicate a sufficient amount of time to prepare their brief in opposition by the current due date. Counsel for both parties are currently engaged in various stages of discovery, trial preparation, and alternative dispute resolution procedures in numerous closely-related lawsuits pending before the Court. Plaintiffs recently completed and served their preliminary proposed findings of fact, exhibits list and witness list in

Case 1:98-cv-00726-EJD

Document 158

Filed 04/08/2005

Page 2 of 2

this matter, and are currently engaged in expert discovery in this case as well. In addition, the parties are heavily engaged in discovery and discussions regarding several related cases that have been referred to the Court's Alternative Dispute Resolution Pilot Program. Finally, counsel also have various recent and upcoming filings and deadlines in a number of other related cases, including Apache Apartments v. United States, No. 96-700C, Carpenter v. United States, No. 0401740, and Allegre Villa v. United States, No. 98-823C. Accordingly, plaintiffs respectfully requests that the Court grant this Unopposed Motion for Enlargement of Time for good cause shown and extend the current deadline for filing their Opposition to Defendant's Motion to Dismiss by four days up to and including April 15, 2005.

Dated: April 8, 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