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

Case 1:06-cv-00232-LMB

Document 24

Filed 03/16/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

SYSTEMS DEVELOPMENT CORPORATION, Plaintiff, v. UNITED STATES, Defendant.

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Case No. 06-232 C (Judge Baskir)

JOINT MOTION TO AMEND SCHEDULING ORDER Come now the Plaintiff, Systems Development Corporation, and the Defendant, the United States, and request this Court to amend the Scheduling Order entered by the Court on October 18, 2006. Since the entry of the original scheduling order, the parties have been diligent in pursuing discovery. The parties have taken and responded to written discovery, and have also taken depositions of fact witnesses. The parties cooperated in resolving the scheduling difficulties created by the conflicting travel schedules of counsel and the fact that some of the Government's witnesses have retired from the Government, but the result was that depositions could not be completed until this week. Therefore, the parties request a short extension of the discovery

Case 1:06-cv-00232-LMB

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deadline and related deadlines. This is the parties' first request for an extension for this purpose. Specifically, the parties request the following modifications: 1. The Parties request that the March 16, 2007 deadline for fact

and expert discovery be extended by forty-five (45) days, until April 26, 2007. 2. The Parties request that the January 19, 2007 deadline for

the Plaintiff's expert reports be extended by sixty-one (76) days, until April 5, 2007. 3. The Parties request that the February 20, 2007 deadline for

the Defendant's expert reports be extended by sixty-one (76) days, until May 7, 2007. 4. The Parties request that the March 23, 2007, deadline for the

Joint Status Report be extended by forty-five (45) days, until May 7, 2007. WHEREFORE, the premises considered, the Plaintiff moves this Honorable Court to amend the Scheduling Order entered by this Court on October 18, 2006.

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Respectfully Submitted By:

/s/ Howell Roger Riggs Attorney for the Plaintiff Dick, Riggs, Miller & Stem, LLP 200 Clinton Avenue West AmSouth Center, Suite 1050 Huntsville, Alabama 35801 Tel: (256) 564-7317 Fax: (256) 564-7319 [email protected]

/s/ Joan M. Stentiford Attorney for the Defendant Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 616-0341 Fax: (202) 514-8624 [email protected]