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

Case 1:02-cv-00796-FMA

Document 62

Filed 09/22/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS INFORMATION SYSTEMS & NETWORKS CORPORATION, Plaintiff, ) ) ) ) ) ) ) ) ) ) )

No. 02-796C (Judge Allegra)

v. THE UNITED STATES, Defendant.

JOINT MOTION FOR ENLARGEMENT OF THE DISCOVERY DEADLINE Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, the parties respectfully request this Court to enlarge by 120 days, to and including January 30, 2007, the deadline for discovery in this case. The current discovery deadline is October 2, 2006. This is the parties' second motion to enlarge the discovery deadline. The Court granted the parties' first motion, which requested a 125-day enlargement of the discovery deadline on May 11, 2006. The parties have discussed the remaining necessary discovery and believe that it can be completed within the time period requested. This motion is necessary because the Government counsel formerly responsible for representing the United States in this case, Doris Finnerman, recently left the employment of the Department of Justice and consequently, a new government counsel was assigned to this case on September 19, 2006.1 As a result defendant's new counsel needs additional time to become familiar with the case, contact counsel for the
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Defendant's new counsel, Anuj Vohra, is in the process of being admitted to practice before this Court. Because his admission is not yet complete, Mr. Vohra's name does not appear in the signature block below.

Case 1:02-cv-00796-FMA

Document 62

Filed 09/22/2006

Page 2 of 2

governmental agencies involved, assess the status of discovery, and prepare for any necessary depositions. Indeed, on September 14, 2006, plaintiff's counsel served defendant with notices of depositions of two former and two current Defense Contract Audit Agency ("DCAA") employees. The identified former employees have not yet been located, and the parties have not yet scheduled those depositions. Granting the requested enlargement should not cause any material inconvenience, and will not affect any other court-ordered deadlines. Accordingly, the parties respectfully request that this Court enlarge, by 120 days, to and including January 30, 2007, the deadline for discovery in this matter. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

DAVID M. COHEN Director

s/ Norman H. Singer NORMAN H. SINGER Singer & Associates, P.C. 10411 Motor City Drive 7th Floor Bethesda, MD 20817 Phone: (301) 469-0400 Fax: (301) 469-0403 Attorney for Plaintiff

s/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Washington, DC 20005 Phone: (202) 514-4325 Fax: (202) 307-0972 Attorneys for Defendant

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