Free Response - District Court of Federal Claims - federal

Case 1:07-cv-00056-EJD

Document 26

Filed 12/03/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BASS MANAGEMENT, INC. VS. UNITED STATES OF AMERICA PLAINTIFF'S JOINDER IN DEFENDANT'S MOTION FOR EXTENSION OF TIME FOR FACT DISCOVERY Bass Management, Inc. joins with the Defendant in mutually requesting the Court enlarge the discovery period through February 5, 2007. The parties have made great strides in settlement negotiations which, if finalized, will moot the need for additional discovery. Indeed, presently it appears that the parameters of a settlement in principle have been determined, subject to Bass Management's attempt to resolve the contractual and financial problems presented by its sublease with Hill's Lake Escape. [Any settlement would also be subject to review and approval of DOJ supervisory level officials.] Furthermore, without conceding Defendant's various CIVIL ACTION NO. 1:07cv00056

contention of inadequate discovery responses, the additional time will enable the parties seek an amicable resolution of Defendant's concerns without having to bring the matter before the Court.

Respectfully submitted,

BY:

/s/Frank W. Trapp____________ Frank W. Trapp, MB #8261 PHELPS DUNBAR LLP 111 East Capitol Street · Suite 600 Jackson, Mississippi 39201-2122 P. O. Box 23066 Jackson, Mississippi 39225-3066 Telephone: (601) 352-2300 Telecopier: (601) 360-9777

JO.99372809.1

Case 1:07-cv-00056-EJD

Document 26

Filed 12/03/2007

Page 2 of 2

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been served on the following counsel of record by ECF and U.S. Mail, properly addressed and postage prepaid: David M. Hibey, Esq. U. S. Department of Justice Civil Division 1100 L. Street NW Washington, DC 20530 THIS the 2nd day of December, 2007.

/s/Frank W. Trapp Frank W. Trapp

JO.99372809.1