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

Case 1:06-cv-00345-EGB

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Filed 03/23/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GRACE AND NAEEM UDDIN, INC., Plaintiff, v. ) ) ) ) ) ) ) ) ) )

No. 06-345C (Judge Bruggink)

THE UNITED STATES, Defendant.

DEFENDANT'S UNOPPOSED MOTION TO MODIFY DISCOVERY SCHEDULE Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests the Court to modify the discovery schedule in this case as outlined below. This is defendant's first motion for this purpose.1 Counsel for defendant has contacted counsel for plaintiff regarding this request and has been advised that plaintiff does not oppose the schedule modification. This motion is necessary because of the impending departure of undersigned trial counsel for the Government from the Department of Justice, which is scheduled for March 23, 2007. Because new counsel for the Government has not been assigned and will require a brief period to become familiar with the case, the

The parties filed a joint request to modify the schedule which the Court granted in an order dated February 12, 2007.

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Case 1:06-cv-00345-EGB

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additional time contemplated by the requested schedule modification is necessary. The requested schedule modification should provide new counsel sufficient time to become familiar with the case, and to allow the parties to complete discovery. Accordingly, defendant respectfully requests the Court to adopt the following modifications to the existing schedule established in the Court's February 12, 2007 order: Deadline for Completion of Written Discovery Deadline for Completion of Fact Discovery Deadline for Expert Disclosures Pursuant to RCFC 26(a) Close of All Discovery May 28, 2007 July 23, 2007 September 24, 2007

November 16, 2007 Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director /s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director

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/s/ Gregory T. Jaeger GREGORY T. JAEGER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 (202) 353-7955 March 23, 2007 Attorneys for Defendant

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CERTIFICATE OF FILING I hereby certify that on March 23, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION TO MODIFY 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/Gregory T. Jaeger