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 December 15, 2006 Order, the Court set deadlines as follows: Exchange of Initial Disclosures Close of Fact Discovery Disclosure of Expert Witnesses 2. January 15, 2007 April 27, 2007 July 15, 2007

The parties are in the process of written discovery, and are conferring on dates for

depositions. The parties need additional fact discovery time for these depositions, and any follow up written discovery. Based on counsel's conferences regarding scheduling, Meredith believes that the parties need an additional three (3) months for fact discovery. 3. Meredith proposes a new fact discovery deadline of July 27, 2007, and a deadline

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for disclosure of expert witnesses of October 15, 2007. The joint status report addressed in the Court's December 15, 2006 order would then be submitted August 6, 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 three (3) months for fact discovery, so that the deadline for fact discovery is July 27, 2007 and the deadline for the disclosure of expert witnesses is October 15, 2007.

Respectfully submitted,

__________ /s/ ___________ DONNA M.B. KING 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 27th day of April 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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