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

Case 1:07-cv-00004-TCW

Document 25

Filed 02/12/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS LAUDES CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant. PLAINTIFF'S UNOPPOSED MOTION TO AMEND SCHEDULING ORDER Pursuant to Rule 6(b) and 7 of the United States Court of Federal Claims, Plaintiff moves the Court to amend its November 19, 2007 scheduling order (Doc. No. 24) by extending the deadlines therein by 90 days. Plaintiff's counsel has discussed this motion with Government counsel who has represented that the Government does not oppose this request. Plaintiff requests additional time in order to review and analyze the documents recently produced by the Government. Specifically, in response to Plaintiff's requests for Rule 56(f) discovery, the Government produced documents on January 15, 2008 and again on January 21, 2008. To date, the Government has produced several thousand pages of documents relating to the issues raised in the Government's Motion for Partial Summary Judgment. As the Government recognized in its November 16, 2007 Motion to Amend Scheduling Order (Doc. 23), the timing of this document production impacts Plaintiff's follow-on discovery and makes it difficult to complete this discovery according to the deadlines reflected in the Court's November 19, 2007 scheduling order. This recently produced discovery may also lead to updates to the Government's interrogatory responses. For these reasons, Plaintiff needs additional time to review the Government's recently produced documents and to incorporate this material into Plaintiff's surreply to the Motion for Partial Summary Judgment. No. 07-4C (Judge Wheeler)

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Case 1:07-cv-00004-TCW

Document 25

Filed 02/12/2008

Page 2 of 2

Accordingly, Plaintiff requests that the Court grant this unopposed motion and enlarge the deadlines in the Court's November 19, 2007 order by 90 days. DATED this 12th day of February, 2008. Respectfully submitted, LAUDES CORPORATION

By:__s/Mark G. Jackson Mark G. Jackson, WSBA #18325 GARVEY SCHUBERT BARER 1191 Second Avenue, Suite 1800 Seattle, Washington 98101 (206) 464-3939 (206) 464-0125 ­ fax Counsel of Record for LAUDES CORPORATION

SEA_DOCS:877424.1