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

Case 1:06-cv-00451-EGB

Document 23-2

Filed 01/25/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JOHN MEREDITH, Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant. * * * * * * * * * * * * * * * * * * No. 06-451C (Judge E. Bruggink)

PLAINTIFF JOHN MEREDITH'S RULE 37 CERTIFICATION In support of Plaintiff John Meredith's Motion to Compel, counsel for Meredith provides the following statement of good faith attempts to resolve its discovery dispute, as follows: 1. On January 9, 2008, Meredith and Defendant United States of America

("United States") conferred on United States' objections to Interrogatory No. 2 of Meredith's Second Set of Interrogatories and Document Request Nos. 3 and 4 of Meredith's Second Set of Document Requests. 2. During the process of conferring, and in an effort to address

confidentiality concerns, Meredith offered to drop his request for the salary of the listed persons and receive only the GS level and grade of the person. 3. On January 23, 2008, the parties spoke again by telephone on the United

States' objections to the above-referenced discovery. Counsel for the United States stated during the telephone call that the United States rejected that offer of compromise.

Case 1:06-cv-00451-EGB

Document 23-2

Filed 01/25/2008

Page 2 of 2

4.

The undersigned counsel certifies that she has been unable to resolve this

discovery dispute, and files the Motion to Compel after the above-described efforts to reach a resolution.

__________ ___________________ Donna M.B. King Law Office of Donna M.B. King, LLC 309 West Pennsylvania Avenue Towson, Maryland 21204 (410) 494-1005 Attorney for Plaintiff John Meredith

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