ML21067A083

3-8-21 Unopposed Motion for Enlargement of Time to Comply with Docketing Order (Refiled)(Dc Cir.)(Case No. 21-1048)

ML21067A083
Person / Time
Site:	Consolidated Interim Storage Facility
Issue date:	03/08/2021
From:	Lodge T Don't Waste Michigan, Law Offices of Terry Jonathan Lodge
To:	NRC/OGC, US Federal Judiciary, Court of Appeals, for the District of Columbia Circuit
References
1888684, 21-1048, 21-1056
Download: ML21067A083 (4)

Text

UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT Dont Waste Michigan, et al.,

Petitioners,

v.

U.S. Nuclear Regulatory Commission and United States of America, Respondents.

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Case No. 21-1048 (Consolidated with 21-1056)

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(REFILED) UNOPPOSED MOTION FOR ENLARGEMENT OF TIME 1

TO COMPLY WITH DOCKETING ORDER Now come Dont Waste Michigan, et al., by and through counsel, and move the Court to reschedule the various milestone dates established in its February 3, 2021 Order in this case, by moving them back 7 days.

/s/ Terry J. Lodge Terry J. Lodge, Esq.

316 N. Michigan St., Suite 520 Toledo, OH 43604-5627 (419) 205-7084 tjlodge50@yahoo.com Counsel for Petitioners Dont Waste Michigan, et al.

This is a refiling of the Unopposed Motion filed by Petitioners on March 5, 1

2021. USCA Case #21-1048 Document #1888684 Filed: 03/08/2021 Page 1 of 4

MEMORANDUM IN SUPPORT The February 3, 2021 docketing order issued by the Court set several deadlines for Petitioners to address by March 5, 2021. Counsel for Petitioners is not able to meet those deadlines because of several current priority legal matters which also require his attention by and before March 5, 2021. Petitioners thus request a one-week extension of time to comply with the February 3, 2021 Order, including a commensurate extension of the Respondents filing deadlines also enumerated in that Order.

Counsel has consulted with opposing counsel for the United States, the U.S.

Nuclear Regulatory Commission, and Interim Storage Partners, the Intervenor. All opposing counsel have stated that they do not oppose this request.

The milestones and proposed new deadline dates follow:

For Petitioners:

Certificate as to Parties, Rulings, and Related Cases March 12, 2021 Docketing Statement Form March 12, 2021 Procedural Motions, if any March 12, 2021 Statement of Intent to Utilize Deferred Joint Appendix March 12, 2021 Statement of Issues to be Raised March 12, 2021 Underlying Decision from Which Appeal or Petition Arises March 12, 2021 USCA Case #21-1048 Document #1888684 Filed: 03/08/2021 Page 2 of 4

Dispositive Motions, if any (Original and 4 copies)

March 29, 2021 For Respondents:

Entry of Appearance Form March 12, 2021 Procedural Motions, if any March 12, 2021 Certified Index to the Record March 29, 2021 Dispositive Motions, if any (Original and 4 copies)

March 29, 2021 WHEREFORE, Petitioners pray the Court grant them the requested extensions together with commensurate extensions for Respondents.

/s/ Terry J. Lodge Terry J. Lodge. Esq.

Counsel for Petitioners CERTIFICATE OF COMPLIANCE OF UNOPPOSED MOTION FOR ENLARGEMENT OF TIME WITH RULE 32(G) TYPE-VOLUME LIMITATION Petitioners Unopposed Motion for Enlargement of Time to Comply with Docketing Order complies with the type-volume limitation of Fed.R.App.P. 32(g) because it contains 279 words, according to the word count maintained by Petitioners WordPerfect word processing program, exclusive of signature blocks.

/s/ Terry J. Lodge Terry J. Lodge, Esq.

Counsel for Petitioners Dont Waste Michigan, et al.

CERTIFICATE OF SERVICE USCA Case #21-1048 Document #1888684 Filed: 03/08/2021 Page 3 of 4

I hereby certify that a copy of the foregoing Unopposed Motion was deposited by me in the Courts Electronic Case Filing system on March 7, 2021, and that according to the protocols of the ECF system, the same was distributed to all counsel of record.

/s/ Terry J. Lodge Terry J. Lodge Counsel for Petitioners USCA Case #21-1048 Document #1888684 Filed: 03/08/2021 Page 4 of 4