Free Motion for Extension of Time to Complete Discovery - 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 UNOPPOSED 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 August 1, 2007 Order, the Court extended the discovery deadline to

September 25, 2007, set a status report date of October 4, 2007, with a teleconference to be scheduled thereafter. 2. The parties served additional written discovery, and are conferring on dates for

two final depositions. Therefore, the parties need additional fact discovery time for these depositions and written discovery. Based on counsel's conferences regarding scheduling, Meredith believes that the parties need only an additional forty-five (45) days for fact discovery. 3. Meredith proposes a new fact discovery deadline of November 9, 2007, and a

deadline for disclosure of expert witnesses of January 28, 2008. The joint status report

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addressed in the Court's August 1, 2007 order would then be submitted November 21, 2007. 4. Defendant does not oppose 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 forty-five (45) for fact discovery, so that the deadline for fact discovery is November 9, 2007 and the deadline for the disclosure of expert witnesses is January 28, 2008.

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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CERTIFICATE OF FILING I hereby certify that upon this 25th day of September 2007, a copy of the foregoing Plaintiff John Meredith's Unopposed 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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