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

Case 1:07-cv-00126-LMB

Document 17

Filed 12/19/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SI-NOR INCORPORATED, a California corporation, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-126C (Judge Lawrence M. Baskir)

JOINT MOTION FOR ENLARGEMENT OF FACT DISCOVERY DEADLINE Pursuant to RCFC 6(b), the parties respectfully request an enlargement of time of 60 days, to and including February 29, 2008, to complete fact discovery. Discovery is currently scheduled to close on December 31, 2007. This is the parties' first request for an enlargement of time for this purpose. An enlargement of time is necessary to enable plaintiff to complete its production to the defendant and to the DCAA auditor in this case, to allow defendant time to review the production, and to afford both parties an opportunity to depose necessary witnesses with the benefit of that discovery.

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Case 1:07-cv-00126-LMB

Document 17

Filed 12/19/2007

Page 2 of 3

For the foregoing reasons, the parties respectfully request an enlargement of 60 days, to and including February 29, 2008 to complete fact discovery in this case. Respectfully submitted, JEFFREY S. BUCKHOLTZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director

s/ Deborah A. Bynum DEBORAH A. BYNUM Assistant Director

s/ Joseph D. Curd JOSEPH D. CURD Curd, Galindo & Smith 301 E. Ocean Boulevard Suite 1700 Long Beach, CA 90802 Tel: (562) 624-1177 Fax: (562) 624-1178

s/ A. Bondurant Eley A. BONDURANT ELEY Trial Attorney Commercial Litigation Branch Department of Justice 1100 L St., N.W. Classification Unit, 8th Floor Washington, D.C. 20530 Tel: (202) 616-8254 Fax: (202) 514-8624 Counsel for Defendant

Counsel for Plaintiff December 19, 2007

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Case 1:07-cv-00126-LMB

Document 17

Filed 12/19/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 19th day of December, 2007, a copy of the foregoing "JOINT MOTION FOR ENLARGEMENT OF FACT DISCOVERY DEADLINE" 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.

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