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Case 1:05-cv-01119-SGB Document 25 Filed 10/02/2006 Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

ROCCO TOMMASEO, and
THOMAS TOMMASEO, and
ROCKY AND CARLO, INC., and
STEVEN BORDELON, husband of,
and CYNTHIA BORDELON and,
STEVE’S MOBILE HOME & R.V. REPAIR,
INC.


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UNITED STATES OF AMERICA,

Defendant.

Plaintiffs,

v.

No. 05-1119L

Hon. Susan G. Braden

MOTION FOR ENLARGEMENT OF TIME IN WHICH TO FILE DEFENDANT’S

MOTION TO DISMISS PLAINTIFFS’ COMPLAINT

_____________________________________________________________________________

Defendant, United States of America, hereby moves for an enlargement of time of two

business days, or to and including October 4, 2006, for the filing of the United States’ Motion to

Dismiss Plaintiffs’ First Amended Complaint.

At present, Defendant’s Motion is due October 2, 2006, pursuant to the Court’s order of

September 8, 2006.

No previous enlargements of time of this deadline have been requested.

Defendant regrets the inconvenience that might befall the Court due to the proximity of

this motion to the due date of Defendant’s Motion to Dismiss. Of course, Defendant worked

diligently to complete the Motion by its original due date. Nonetheless, today’s holiday, Yom

Kippur, has necessitated that Defendant request this additional time. Further, the two additional

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Case 1:05-cv-01119-SGB Document 25 Filed 10/02/2006 Page 2 of 2

days will not unduly prejudice Plaintiffs because, per the September 8, 2006 order, the due date

of their response is indexed to the date they receive the Motion.

On October 2, 2006, counsel for the Defendant conferred with counsel for the Plaintiffs

who indicated that they do not object to this enlargement.

WHEREFORE, Defendant respectfully requests a two day enlargement of time in which to file

its Motion to Dismiss.

Dated: October 2, 2006

SUE ELLEN WOOLDRIDGE
Assistant Attorney General
Environment and Natural Resources Division

s/ Fred Disheroon by Mark T. Romley
FRED R. DISHEROON, Special Litigation Counsel
MARK T. ROMLEY, Trial Attorney
Natural Resources Section
Environment and Natural Resources Division
U.S. Department of Justice
601 D. St. N.W., Room 3022
Washington, D.C. 20004
Telephone: (202) 616-9649
Fax: (202) 616-9667

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