Free Motion to Amend Schedule - District Court of Federal Claims - federal

Case 1:07-cv-00355-NBF

Document 15

Filed 03/31/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TEXAS NATIONAL BANK f/k/a MERCEDES NATIONAL BANK Plaintiff, VS. UNITED STATES Defendant. § § § § § § § § § §

NO. 07-00355C Judge Firestone

JOINT MOTION TO AMEND SCHEDULING ORDER Come now the Plaintiff and Defendant, and requests this Court to amend the Scheduling Order entered by the Court on October 24, 2007. Since the entry of the original scheduling order, the parties have been diligent in pursuing discovery. The parties have taken and responded to written discovery, and have also taken depositions of fact witnesses in Mercedes, Texas. The parties have also agreed to take depositions in Indianapolis this week. In doing so, the parties have cooperated in resolving the scheduling difficulties created by the conflicting travel schedules of counsel. However, the parties have recently agreed to enter into settlement negotiations at this time, and desire to forego the expense of additional travel and depositions at this time in order to allow these settlement discussions to proceed. Therefore, the parties request a short, forty-five (45) day extension of the discovery deadline and related deadlines. This is the parties' first request for an extension for this purpose. Specifically, the parties request the following modifications: 1. The Parties request that the March 31, 2008 deadline to complete discovery be

extended by forty-five (45) days, until May 15, 2008.

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Case 1:07-cv-00355-NBF

Document 15

Filed 03/31/2008

Page 2 of 2

2.

The Parties request that the April 7, 2008, deadline for the Joint Status Report be

extended by sixty (60) days, until May 30, 2008. WHEREFORE, the premises considered, the parties move this Honorable Court to amend the Scheduling Order entered by this Court on October 24, 2007.

JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/Mark A. Melnick MARK A. MELNICK Assistant Director s/ Joan M. Stentiford JOAN M. STENTIFORD Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 616-0341 Fax: (202) 514-8624

s/ Edward C. Snyder EDWARD C. SNYDER Castillo Snyder, P.C. Bank of America Plaza, Suite 1020 300 Convent Street San Antonio, Texas 78205 Phone (210) 630-4200 Fax (210) 630-4210

Attorney for Plaintiff

Attorneys for Defendant

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