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

Case 1:08-cv-00028-CCM

Document 11

Filed 06/05/2008

Page 1 of 1

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

COMMODITY SOLUTIONS, LLC, Plaintiff, v. UNITED STATES OF AMERICA, Defendant.

) ) ) ) ) ) ) ) ) ) )

No. 08-28C (Judge C. Miller)

UNOPPOSED MOTION FOR EXTENSION OF TIME FOR PARTIES TO EXCHANGE INITIAL DISCOVERY DISCLOSURES Plaintiff Commodity Solutions, LLC ("Commodity") requests that, notwithstanding this Court's Order filed June 2, 2008, the time within which voluntary disclosures must be exchanged by the parties be extended from June 6, 2008 to and including June 17, 2008. The reason for this request is that Commodity's representative has been traveling and unable to consult fully with Commodity's legal counsel on these matters. This is the first request for an extension of time with respect to the date for making voluntary disclosures. Counsel for the United States has authorized the undersigned to represent to the Court that he does not oppose this request. Dated: June 5, 2008 OF COUNSEL: George W. Ash Erin L. Toomey FOLEY & LARDNER LLP One Detroit Center 500 Woodward Avenue, Suite 2700 Detroit, MI 48226-3489 Telephone (313) 234-7100 Facsimile (313) 234-2800 Respectfully submitted, /s/ John G. DeGooyer John G. DeGooyer FOLEY & LARDNER LLP 3000 K Street, N.W., Suite 500 Washington, D.C. 20007-5143 Telephone (202) 295-4047 Facsimile (202) 672-5399 Counsel of Record for Plaintiff Commodity Solutions, LLC

1
WASH_4183740.1