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

Case 1:06-cv-00451-EGB

Document 15

Filed 07/26/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JOHN MEREDITH, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 06-451 (Judge Bruggink)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant requests an enlargement of time of 60 days, to and including September 25, 2007, within which to complete discovery. The deadline for the

completion of fact discovery in this case currently is July 27, 2007. In addition, defendant requests a corresponding

enlargement of time of 60 days, to and including October 4, 2007, within which to submit the parties' joint status report regarding the completion of discovery. This is our first request for an

enlargement of time for these purposes; plaintiff previously requested and was granted an enlargement of 90 days of the aforementioned deadlines. Plaintiff's counsel has been contacted

and does not oppose this request for an enlargement of time. On May 1, 2007, the Court issued an order, at plaintiff's request, that the close of discovery be changed from April 27, 2007 to July 27, 2007. Since that time, the parties have made Defendant has deposed

considerable progress in discovery.

plaintiff, and plaintiff has deposed defendant pursuant to RCFC 30(b)(6). In addition, the parties have exchanged documents, and

Case 1:06-cv-00451-EGB

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defendant has responded to interrogatories served by plaintiff. Due to the difficulty in scheduling depositions during the summer months, however, the parties require additional time in which to complete discovery. The parties have conferred, and agree that

an additional 60 days should be sufficient to complete discovery in this case. For the foregoing reasons, defendant requests that the Court grant this motion for an enlargement of time to complete discovery and a corresponding enlargement of time within which to submit a joint status report.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Todd M. Hughes TODD M. HUGHES Deputy Director s/ Robert E. Chandler Robert E. Chandler Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L St., N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 307-1011 Attorneys for Defendant July 26, 2007

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CERTIFICATE OF FILING

I hereby certify that on this 26th day of July 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" 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. through the Court's system. Parties may access this filing

s/ Robert E. Chandler