Free Motion to Continue - District Court of Federal Claims - federal

Case 1:07-cv-00080-MCW

Document 9

Filed 01/14/2008

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UNITED STATES COURT OF FEDERAL CLAIMS

TPI CONSTRUCTION, INC.,
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Plaintiff, v. UNITED STATES; DEPARTMENT OF THE ARMY Defendant.

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USCFC No. 07-80C

Judge Mary Ellen Coster Williams

Plaintiff, by and through its counsel of record, respectfully requests this Court continue the discovery deadline of February 1, 2008 to April 1, 2008 and the expert discovery date to June 1, 2008. No other dates need be continued. This Court's Order filed June 5, 2007 established dates for fact discovery, expert exchanges and pretrial filings. The parties have exchanged written discovery with the exception that document discovery is still ongoing. The parties expect to complete document exchange by January 31, 2008 and need an additional 60 days to complete depositions. Depositions of all witnesses are currently planned for the weeks of March 10, 2008 and March 17, 2008, which are the first weeks convenient to the witnesses' and counsels' calendars. It is therefore requested that all discovery dates be continued 60 calendar days to an including April 1, 2008, with expert discovery continued to June 1, 2008. All other dates to remain as indicated in this Court's June 5, 2007 Order. Plaintiff's counsel that he joins in this Motion. // // // // Defendant's counsel has advised

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Case 1:07-cv-00080-MCW

Document 9

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Dated: January 14, 2008

Respectfully Submitted,

/s/ William L. Bruckner William L. Bruckner BRUCKNER & WALKER 4550 Kearny Villa Road, Ste 209 San Diego, CA 92123 ((858) 565-8300 Telephone (858) 565-0813 Facsimile [email protected]

Attorneys for TPI CONSTRUCTION, Inc.

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Case 1:07-cv-00080-MCW

Document 9

Filed 01/14/2008

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CERTIFICATE OF SERVICE

I hearby certify under penalty of perjury that o this 14th day of January, 2008, a copy of the forgoing Motion 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 courts system.

s/ Tiffany Adams

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