Free Motion to Amend Schedule - District Court of Federal Claims - federal

Case 1:06-cv-00354-MBH

Document 15

Filed 04/30/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ | AMERICAN CASUALTY CO. | OF READING, PENNSYLVANIA | | Plaintiff, | | v. | | UNITED STATES | | Defendant. | __________________________________________|

CoFC No. 06-354C

JOINT MOTION FOR AN EXTENSION OF DISCOVERY PERIOD AND ASSOCIATED DATES. Pursuant to Rule 6.1 of the Rules of this Court and the Federal Rules of Civil Procedure, Plaintiff American Casualt y Co. of Reading, Pennsylvania ("American Casualty") and the Defendant, the United States of America, ("United States") hereby move for an extension of the discovery period in this case by approximately 60 days and an extension of related dates as follows: 1. Discovery will close on or before Friday, July 20, 2007. 2. Amended Pleadings or Rule 14 motions due by July 27, 2007. 3. Joint Status Report due by August 17, 2007. In support of this motion, and in accordance with the requirements of Rule 6.1, the parties state there have been no previous motions for enlargement of time in this case. The reason for this motion for extension of time is due to delay encountered by the United States in obtaining discovery documents from certain geographically dispersed facilities located in California, as described in the Joint Status Report filed with this

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Case 1:06-cv-00354-MBH

Document 15

Filed 04/30/2007

Page 2 of 2

Court on February 28, 2007, and the resultant delay in providing those documents to the Plaintiff. The parties in informed the Court in the February 28, 2007 Status Report that it was likely discovery would need to be extended and that the parties would cooperate in providing a reasonable request to the Court. WHEREFORE, American Casualty and the United States move this Court for an order extending discovery and the schedule in this case, as stated above.

Respectfully submitted, /s/ Victor G. Klingelhofer Victor G. Klingelhofer Cohen Mohr, LLP 1055 Thomas Jefferson St., NW, Suite 504 Washington, DC 20007 Tel. (202) 342-2550 Fax (202) 342-6147 Counsel for Plaintiff

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Donald E. Kinner DONALD E. KINNER Assistant Director s/ Joan M. Stentiford JOAN M. STENTIFORD Trial Attorney Commercial Litigation Branch Civil Division Departme nt of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 616-0341 Fax: (202) 514-8624 Attorneys for Defendant

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