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

Case 1:06-cv-00312-TCW

Document 13

Filed 05/08/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS MULTISERVICE JOINT VENTURE LLC, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 06-312C (Judge Wheeler)

JOINT MOTION FOR ENLARGEMENT OF THE DISCOVERY SCHEDULE Pursuant to Rules 6(b) and 29 of the Rules of the United States Court of Federal Claims "RCFC"), the parties respectfully request that the Court enlarge the period of discovery by 98 days, so that discovery will complete by Friday, October 5, 2007. Discovery currently is scheduled to close on June 29, 2007. This is the parties' first request for an enlargement for this purpose. The parties also request the following modifications to intervening dates set forth in the Courts' September 29, 2006 scheduling order: · · · Plaintiff's expert reports due July 16, 2007; Defendant's expert reports due August 16, 2007; Expert depositions to be complete by October 5, 2007.

The parties request these modifications to the discovery schedule because the initial schedule that the parties agreed upon has proven to be too aggressive in light of both counsels' other case obligations and constraints upon counsels' time. Specifically, counsel for the United States has had substantial time constraints as a result of commitments in more than 20 active that have had briefing or other deadlines, depositions, or hearings during the discovery period, as well as a continuing family emergency due to a relative's illness. Counsel for the plaintiff has experienced and anticipates further significant constraints as well. To date, counsel have

Case 1:06-cv-00312-TCW

Document 13

Filed 05/08/2007

Page 2 of 3

Case 1:06-cv-00312-TCW

Document 13

Filed 05/08/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 8th day of May, 2007, a copy of the foregoing "JOINT MOTION FOR ENLARGEMENT OF THE 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/ Brian T. Edmunds