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

Case 1:06-cv-00211-VJW

Document 34

Filed 07/02/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

No. 06-211 T (Judge Victor J. Wolski) JAMES R. THOMPSON, Plaintiff v. THE UNITED STATES, Defendant UNOPPOSED MOTION TO AMEND SCHEDULING ORDER NOW COMES James R. Thompson, Plaintiff, by his undersigned attorney, and submits this Unopposed Motion to Amend Scheduling Order and, in support thereof, would respectfully show the Court as follows: 1. Under the Scheduling Order, oral argument on the parties' cross motions for

summary judgment is currently scheduled for July 19, 2007. The undersigned has developed an unavoidable conflict and must be in Chicago, Illinois on another matter on July 19, 2007. He has conferred with Jeff Malo, counsel for the government and Mr. Malo is agreeable to moving the summary judgment hearing to the earliest and next available date which the Court may have. The undersigned respectfully requests that the Court cancel the summary judgment hearing currently set for July 19, 2007 and set a new date thereafter.

UNOPPOSED MOTION TO AMEND SCHEDULING ORDER ­ Page 1

Case 1:06-cv-00211-VJW

Document 34

Filed 07/02/2007

Page 2 of 2

Respectfully submitted, WINSTEAD SECHREST & MINICK P.C. 5400 Renaissance Tower 1201 Elm Street Dallas, Texas 75270-2199 (214) 745-5400 (Phone) (214) 745-5390 (Fax)

By:

/s/ Stuart M. Reynolds, Jr. Thomas R. Helfand, State Bar No. 09392500 Stuart M. Reynolds, Jr., State Bar No. 16805700

ATTORNEYS FOR PLAINTIFF JAMES R. THOMPSON CERTIFICATE OF CONFERENCE The undersigned has conferred by telephone with Jeffrey R. Malo, Defendant's counsel, and Mr. Malo does not oppose the relief requested in this motion. /s/ Stuart M. Reynolds, Jr. One of Counsel CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that on this 2nd day of July, 2007, a true and correct copy of the foregoing was forwarded via first class mail to the following: Jeffrey R. Malo [email protected] U.S. Department of Justice, Tax Division Court of Federal Claims Section Post Office Box 26 Ben Franklin Station Washington, D.C. 20044 /s/ Stuart M. Reynolds, Jr. One of Counsel

Dallas_1\4929049\1 44222-1 7/2/2007

UNOPPOSED MOTION TO AMEND SCHEDULING ORDER ­ Page 2