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

Case 1:03-cv-00177-LMB

Document 63

Filed 11/15/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS RILEY & EPHRIAM CONSTRUCTION CO., INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 03-177C

(Judge Baskir)

JOINT MOTION FOR AN ENLARGEMENT OF TIME TO COMPLETE DISCOVERY Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, the parties respectfully request that the Court enlarge by ninety (90) days, through March 1 2007, the deadline for the parties to complete discovery. Currently, discovery is scheduled to end on December 1, 2006. This is the parties' first such request. As outlined in our joint status report, filed concurrently with this motion, the parties have engaged in written discovery. The parties need sufficient time to schedule depositions of relevant witnesses, to review discovery responses, and take additional discovery, as necessary. Accordingly, we respectfully request that the Court enlarge by ninety (90) days, from December 1, 2006, to and including March 1, 2007, the deadline for fact discovery.

Case 1:03-cv-00177-LMB

Document 63

Filed 11/15/2006

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Respectfully submitted, PETER D. KEISLER. Assistant Attorney General DAVID M. COHEN Director

S/Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director

S/Steven L. Smith STEVEN L. SMITH Smith, Cooksey & Vickstrom, LLC 6060 J.A. Jones Drive Suite 208 Charlotte, NC 28287 Tele: (704) 557-9929 Fax: (704) 557-9932

S/Tara K. Hogan TARA K. HOGAN Trial Attorney Department of Justice Civil Division Commercial Litigation Branch 1100 L. Street, NW Attn: Classification Unit, 8th floor Washington, D.C. 20530 Tel: (202) 616-2228 Fax: (202) 514-8624 Attorneys for Defendant

Attorney for Plaintiff November 15, 2006

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Case 1:03-cv-00177-LMB

Document 63

Filed 11/15/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on November 15, 2006, a copy of the foregoing "JOINT MOTION FOR AN ENLARGEMENT OF TIME TO COMPLETE DISCOVERY" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/ Tara K. Hogan