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

Case 1:07-cv-00134-SGB

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Filed 02/08/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ALIAMANU CONSERVATION PARTNERS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-134C (Judge Braden)

JOINT MOTION TO AMEND THE DISCOVERY SCHEDULE Pursuant to Rule 26 of the Rules of the United States Court of Federal Claims ("RCFC"), plaintiff, Aliamanu Conservation Partners, Inc. ("ACP"), and defendant, the United States, respectfully request that the Court amend its discovery scheduling order of September 27, 2007 as follows : Close of Written and Fact Discovery Disclosure of Expert Reports Deadline for Expert Depositions Filing of All Dispositive Motions September 1, 2008 October 17, 2008 November 30, 2008 December 31, 2008

The proposed schedule takes into account that the parties have not yet determined whether they will employ expert witnesses in resolving their dispositive motions, yet the schedule preserves the parties' ability to employ experts in the event that written and fact discovery suggest that expert testimony would be helpful in resolving the issues. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

Case 1:07-cv-00134-SGB

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s/Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/Timothy H. Power TIMOTHY H. POWER Law Offices of Timothy H. Power 19229 Sonoma Highway Suite 246 Sonoma, CA 95476 Tel: (707) 343-1550 Fax: (707) 343-1552 s/Armando A. Rodriguez-Feo ARMANDO A. RODRIGUEZ-FEO Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L St., NW Washington, D.C. 20530 Tel: (202) 307-3390 Fax: (202) 514-8624 Attorneys for Defendant

Attorney for Plaintiff 8 February _____, 2008

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Case 1:07-cv-00134-SGB

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Filed 02/08/2008

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CERTIFICATE OF FILING 8th I hereby certify that on this ____ day of February, 2008, a copy of foregoing "JOINT MOTION TO AMEND THE DISCOVERY SCHEDULE" 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/ Armando Rodriguez-Feo