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

Case 1:06-cv-00345-EGB

Document 12

Filed 02/09/2007

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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.

JOINT MOTION TO MODIFY DISCOVERY SCHEDULE Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), the parties respectfully request the Court to modify the discovery schedule in this case as outlined below. This is the parties' first request for this purpose. This motion is necessary because of unanticipated delays experienced by the parties in coordinating and completing the initial phases of document production associated with the parties' initial disclosures. In addition, plaintiff recently has assigned new counsel to the case. These circumstances make it necessary to request the below modified schedule. The requested schedule modification should provide the parties sufficient time to complete discovery. Accordingly, the parties propose the following modifications to the existing schedule established in the Court's December 13, 2006 order:

Case 1:06-cv-00345-EGB

Document 12

Filed 02/09/2007

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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

April 13, 2007 June 8, 2007 August 10, 2007

October 5, 2007 Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Acting Director

/s/ David R. Elder DAVID R. ELDER Elder & Lewis, PC Bayview Executive Plaza, Suite 301 3225 Aviation Avenue Coconut Grove, FLA 33133 Tele: (786) 314-5155 Fax: (503) 314-5811 February 9, 2007

/s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director /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 Attorneys for Defendant February 9, 2007

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Case 1:06-cv-00345-EGB

Document 12

Filed 02/09/2007

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CERTIFICATE OF FILING I hereby certify that on February 9, 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