Free Motion for Extension of Time to Complete Discovery - District Court of Federal Claims - federal

Case 1:06-cv-00451-EGB

Document 21

Filed 01/10/2008

Page 1 of 6

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 November 13, 2007 Order, the Court extended case deadlines as follows: (1)

deadline for written discovery requests of November 21, 2007; (2) deadline for response to written discovery requests of December 31, 2007; (3) deadline for all fact discovery of January 8, 2008; (4) deadline for joint status report of January 22, 2008; and (5) deadline for disclosure of expert witnesses of March 24, 2008.. 2. In this discovery time period, the parties served and responded to additional

written discovery, and Plaintiff has taken the deposition of a nonparty witness. 3. Through discovery, Plaintiff has become aware of three other individuals with

information relevant to this matter: Rick Wright, Judy Short and Jenny Keane. Plaintiff and

1

Case 1:06-cv-00451-EGB

Document 21

Filed 01/10/2008

Page 2 of 6

Defendant have agreed to the deposition of Rick Wright, and a Rule 30(b)(6) deposition on the sole issue of the calculation of overtime pay in which Defendant anticipates that either Ms. Short or Ms. Keane would be the designee. 4. Therefore, the parties need additional fact discovery time for this specific

discovery set forth above. 5. The parties also have objected to certain written discovery propounded in this

action. The parties have conferred via telephone on this date in an attempt to resolve these matters. The parties have agreed to respond to issues presented in the teleconference by January 16, 2008. However, if the issues cannot be resolved, the parties will need to move for the Court's assistance. 6. Meredith proposes the following schedule: (1) January 31, 2008 as the deadline

for the above-described depositions 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. 7. 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, and requests that the Court enter a Scheduling Order as attached to this motion.

2

Case 1:06-cv-00451-EGB

Document 21

Filed 01/10/2008

Page 3 of 6

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 Attorney for Plaintiff John Meredith

3

Case 1:06-cv-00451-EGB

Document 21

Filed 01/10/2008

Page 4 of 6

CERTIFICATE OF FILING I hereby certify that upon this 10th day of January 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

4

Case 1:06-cv-00451-EGB

Document 21

Filed 01/10/2008

Page 5 of 6

5

Case 1:06-cv-00451-EGB

Document 21

Filed 01/10/2008

Page 6 of 6