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

Case 1:06-cv-00451-EGB

Document 19

Filed 11/09/2007

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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 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 October 2, 2007 Order, the Court extended case deadlines as follows: (1)

discovery deadline of November 9, 2007; (2) deadline for disclosure of expert witnesses of January 28, 2008; and (3) joint status report deadline of November 21, 2007. 2. In this discovery time period, the parties served and responded to additional

written discovery, have taken an additional deposition, and are working toward setting up the deposition of a nonparty witness. In addition, Defendant has discovered an individual who may have relevant information, and is attempting to contact that person. Based on written discovery responses, the parties believe that additional follow-up written discovery is needed. Therefore, the parties need additional fact discovery time for these depositions and written discovery.

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Case 1:06-cv-00451-EGB

Document 19

Filed 11/09/2007

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Based on counsel's conferences regarding scheduling, the parties believe that they need an additional sixty (60) days for fact discovery. The parties believe that this is the last discovery extension needed to complete fact discovery. 3. Meredith proposes the following schedule: (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. 4. Defendant consents to this motion, and agrees that there is a need for additional

time for fact discovery. WHEREFORE, Plaintiff John Meredith respectfully requests that this Court grant an additional sixty (60) for fact discovery, and requests that the Court enter a Scheduling Order as follows:

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Case 1:06-cv-00451-EGB

Document 19

Filed 11/09/2007

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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

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Case 1:06-cv-00451-EGB

Document 19

Filed 11/09/2007

Page 4 of 4

CERTIFICATE OF FILING I hereby certify that upon this 9th day of November 2007, a copy of the foregoing Plaintiff John Meredith's Consent Motion for 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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