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

Case 1:06-cv-00377-GWM

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Filed 08/07/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

ROME RESEARCH CORPORATION, Plaintiff, Case No. 1:06-cv-377 v. UNITED STATES, Defendant Judge George W. Miller

CONSENT MOTION TO EXTEND DISCOVERY TO FACILITATE DISPOSITION OF TENTATIVE SETTLEMENT Plaintiff Rome Research Corporation, with the concurrence and consent of the Defendant, United States, respectfully requests an extension of the deadline for the completion of discovery and such intervening deadlines established in the Court's orders of July 17, 2007 (doc. no. 28) and July 26, 2007 (doc. no. 30). In support thereof, the Plaintiff states: 1. The Parties have reached a proposed settlement that can be

recommended for approval to the authorized representative of the Attorney General for approval. To expedite the disposition of this case, the Parties also are working to resolve the case through the use of a stipulation of dismissal and contracting action. 2. To facilitate the orderly resolution of this action and to avoid further

litigation expense, counsel for the Parties have agreed that counsel for the Plaintiff submit this motion requesting a one week extension of the deadline for completion of discovery currently scheduled to expire on August 17, 2007 and to modify such

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Case 1:06-cv-00377-GWM

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intervening deadlines established by the Court in its orders of July 17, 2007 (doc. no. 28) and July 26, 2007 (doc. no. 30) (the "Intervening Deadlines". 3. Specifically, the Parties request that the deadline for completion of

discovery be extended to August 24, 2007. The Parties further request that the Parties be permitted to reach agreement with respect to the scheduling of the Intervening Deadlines and such other discovery obligations that remain in the event that the Parties fail to consummate the resolution of this case. stipulations in accordance with RCFC 29. 4. Counsel for the Parties have conferred regarding the relief sought in this The Parties will document such

motion and have agreed that Plaintiff should submit this motion with the consent of the Defendant. CONCLUSION For the foregoing reasons, Plaintiff, with the consent of the Defendant, respectfully requests that the Court extend the deadline for completion of discovery to August 24, 2007 and such intervening deadlines variously established by the Court in its orders of July 17, 2007 (doc. no. 28) and July 26, 2007 (doc. no. 30) as the Parties shall stipulate in accordance with RCFC 29.

Respectfully submitted,

s/ DANIEL B. ABRAHAMS Epstein Becker & Green, P.C. 1227 25th Street, N.W., Suite 600 Washington, D.C. 20037 Tel: (202) 861-1854 Dated: August 7, 2007 ­2­

Case 1:06-cv-00377-GWM

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CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on this 7th day of August, 2007, a copy of the foregoing "Consent Motion to Extend Discovery to Facilitate Disposition of Tentative Settlement" 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/ Daniel B. Abrahams

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