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

Case 1:07-cv-00154-ECH

Document 15

Filed 01/18/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) No. 07-154 C ) Chief Judge Edward J. Damich ) ) ) )

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

JOINT MOTION FOR EXTENSION OF TIME TO CONDUCT LIMITED DISCOVERY DURING THE ALTERNATIVE DISPUTE RESOLUTION PROCESS Plaintiff Norman H. Cohen, Ed.D., and defendant United States (government) jointly move for a one-week extension of time to conduct limited discovery during the alternative dispute resolution (ADR) process. On November 16, 2007, this Court ordered that the parties were to conduct limited discovery by January 18, 2008, as discussed during the November 14, 2007, status conference. Pursuant to this Order, plaintiff contemplated conducting two depositions, one of Ms. Bernice Zaidel, and one of her supervisor Mr. Peter Smith. Plaintiff conducted the deposition of Ms. Zaidel on January 3, 2008. Due to a scheduling conflict with Mr. Smith's consulting obligations, the parties were unable to schedule Mr. Smith's deposition before January 25, 2008. Mr. Smith's deposition is currently scheduled to be conducted by plaintiff on January 25, 2008, at 11:00 a.m., in Emmitsburg, Maryland at FEMA's National Emergency Training Center/Emergency Management Institute. Therefore, the parties request a one-week extension of time from January 18, 2008, to January 25, 2008, to complete limited discovery for the ADR process.

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Case 1:07-cv-00154-ECH

Document 15

Filed 01/18/2008

Page 2 of 2

Also, as set forth in the November 16, 2007 Order, the Court set a status conference for January 25, 2008, at 3:00 p.m. Because Mr. Smith's deposition is scheduled for the same day, the parties request that the Court reschedule the status conference for a day and time that is convenient for the Court. For all of these reasons, the parties respectfully request that they be granted an extension of time to conduct limited discovery during the ADR process, and that the status conference be rescheduled to a date and time that is convenient for the Court. Respectfully submitted, Date: January 18, 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

JEFFREY S. BUCHOLZ Acting Assistant Attorney General JOHN J. FARGO Director

Dated: January 18, 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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