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

Case 1:07-cv-00154-ECH

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Filed 08/15/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) No. 07-154 C ) Judge Emily C. Hewitt ) ) ) )

NORMAN H. COHEN, Ed.D., Plaintiff, v. THE UNITED STATES, Defendant.

JOINT MOTION FOR A SEVEN-MONTH EXTENSION OF TIME FOR ALL DEADLINES SET FORTH IN THIS COURT'S ORDER ON FILED ON FEBRUARY 29, 2008 Plaintiff Norman H. Cohen, Ed.D. (Dr. Cohen), and defendant United States (government) hereby move for a seven-month extension of time for all deadlines that this Court set forth in its February 29, 2008 Order for fact and expert discovery and for the filing of summary judgment motions. The parties need this additional time to complete fact discovery. 1. 2. All factual discovery to be completed by Friday, March 27, 2009. All experts who may be used at trial to present evidence on any liability or damages issue under Rules 702, 703, or 705 of the Federal Rules of Evidence will be disclosed no later than Friday, March 27, 2009. 3. Disclosure of expert reports in compliance with RCFC 26(a)(2)(B) of any expert who may be used at trial to present evidence on any liability or damages issue under Rules 702, 703, or 705 of the Federal Rules of Evidence, for which a party has the burden of proof at trial no later than Thursday, April 30, 2009.

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Case 1:07-cv-00154-ECH

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4.

Disclosure of any expert reports in compliance with RCFC 26(a)(2)(B) of any expert who may be used at trial to present evidence on any liability or damages issue under Rules 702, 703, or 705 of the Federal Rules of Evidence, to rebut any expert testimony offered by a party that has the burden of proof at trial no later than Friday, May 29, 2009.

5.

Any expert witness depositions will take place no later than Friday, July 31, 2009.

6.

All motions for summary judgment must be filed no later than Wednesday, September 30, 2009, provided the parties shall make reasonable efforts from and after July 31, 2009 to ascertain together whether either will file a motion for summary judgment and, if it shall appear that neither will do so, they

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Case 1:07-cv-00154-ECH

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Filed 08/15/2008

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shall promptly notify the court by motion to schedule a status conference to set a schedule for pretrial proceedings and trial. Respectfully submitted, Date: August 15, 2008 s/Jonathan Morley Cohen* JONATHAN MORLEY COHEN Klein & Specter, P.C. 1525 Locust Street 19th Floor Philadelphia, Pennsylvania 19102 E-mail: [email protected] Tel: (215) 772-1000 Fax: (215) 772-1005 *By permission received by e-mail

GREGORY G. KATSAS Assistant Attorney General JOHN J. FARGO Director

Dated: August 15, 2008

s/Susan L. C. Mitchell SUSAN L. C. MITCHELL Attorney Civil Division Department of Justice Washington, D. C. 20530 E-mail: [email protected] Telephone: (202) 616-8116 Facsimile: (202) 307-0345

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