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

Case 1:06-cv-00451-EGB

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) ) ) ) ) )

JOHN MEREDITH, Plaintiffs, v. THE UNITED STATES, Defendant.

No. 06-451C (Judge Bruggink)

PLAINTIFF JOHN MEREDITH'S CONSENT MOTION FOR LIMITED EXTENSION OF DISCOVERY SCHEDULE John Meredith, by and through undersigned counsel, moves to extend the discovery deadlines in the above-captioned action, and states as follows: 1. By January 7, 2008 Order, the Court extended case deadlines as follows: (1)

January 31, 2008 as the deadline for deposition of Rick Wright and a Rule 30(b)(6) witness and for supplementing written discovery on damages on VA's formulas; (2) January 25, 2008 as the deadline for any motions to compel; (3) deadline of February 11, 2008 for joint status report; and (4) deadline for disclosure of expert witnesses of April 24, 2008. 2. Mr. Meredith has now taken the deposition of Rick Wright; however, the parties

were not able to schedule the Rule 30(b)(6) deposition prior to January 31, 2008, and have now scheduled the deposition for February 7, 2008. 3. Meredith proposes a change in the schedule above to permit a deadline of

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February 7, 2008 as the deadline for the Rule 30(b)(6) deposition and a date of February 11, 2008 for supplementing written discovery on damages on VA's formulas. 4. Defendant consents to this motion, and agrees that there is a need for additional

time for the specific fact discovery discussed herein. WHEREFORE, Plaintiff John Meredith respectfully requests that this Court grant additional time for the specific discovery discussed herein.

Respectfully submitted,

__________ /s/ ___________ DONNA M.B. KING Law Office of Donna M.B. King, LLC 309 West Pennsylvania Ave. Towson, Maryland 21204 Tel: (410) 494-1005 Fax: (410) 769-8333 [email protected] Attorney for Plaintiff John Meredith

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CERTIFICATE OF FILING I hereby certify that upon this 4th day of February 2008, a copy of the foregoing Plaintiff John Meredith's Consent Motion for Limited Extension of 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/____ _________ Donna M.B. King

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