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

Case 1:06-cv-00436-MCW

Document 15

Filed 03/15/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ULYSSES, INC. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-436C (Judge Williams)

JOINT MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims ("RCFC"), plaintiff, Ulysses, Inc. ("Ulysses"), and defendant, the United States, respectfully request an enlargement of the discovery schedule. This is the parties' second request for an enlargement of time for this purpose after having been granted an enlargement of 45 days on March 7, 2007. On March 8, 2007, this case was assigned to undersigned counsel for the United States. Additional time is needed to permit newly-assigned counsel adequate time with which to familiarize himself with the facts of, and to complete discovery in, this case. Therefore, the parties jointly request the Court to enter the following schedule:

1. 2.

Written Fact Discovery. All written fact discovery to conclude May 14, 2007. Depositions of Fact Witnesses. All depositions of fact witnesses to be completed by July 13, 2007.

3.

Dispositive motions. Defendant to file on or before August 9, 2007. Plaintiff's response and/or cross-motion to be filed on or before September 4, 2007. Defendant's reply to be filed on or before September 25, 2007. Plaintiff's reply to be filed on October 15, 2007.

Case 1:06-cv-00436-MCW

Document 15

Filed 03/15/2007

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

s/ Deborah A. Bynum DEBORAH A. BYNUM Assistant Director

s/ Sam Z. Gdanski SAM Z. GDANSKI SCOTT GDANSKI GDANSKI & GDANSKI, LLP 3 Rockwood Lane Suffern, NY 10901 Washington, D.C. 20007 Tel: (845) 362-4800 Fax: (845) 362-4700 Attorneys for Plaintiff March 15, 2007

s/ Matthew H. Solomson MATTHEW H. SOLOMSON Trial Attorney Commercial Litigation Civil Division U.S. Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 353-4175 Fax: (202) 514-7965 Attorneys for Defendant

2

Case 1:06-cv-00436-MCW

Document 15

Filed 03/15/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 15th day of March, 2007, a copy of the foregoing JOINT MOTION FOR EXTENSION 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. Parties may access this filing through the Court's system.

s/ Matthew H. Solomson