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

Case 1:06-cv-00101-FMA

Document 15

Filed 03/19/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

JAY CASHMAN, INC., Plaintiff, v. THE UNITED STATES, Defendant.

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No. 06-101C (Judge Allegra)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO COMPLETE DISCOVERY Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, defendant respectfully request that the Court enlarge by 56 days, through May 25, 2007, the deadline for the parties to complete discovery. Currently, discovery is scheduled to end on March 30, 2007. Defendant has consulted with counsel for plaintiff, and counsel for plaintiff has represented that plaintiff does not oppose this motion for an enlargement. On January 26, 2007, the parties filed a joint motion to extend discovery through March 30, 2007. On January 29, 2007, the Court issued an Order granting the joint motion to extend discovery. On February 20, 2007, plaintiff produced seven DVDs containing the equivalent of 444 CDs of electronic data responsive to defendant's discovery requests. Defendant requires additional time to review this substantial volume of electronic data, and to schedule depositions of relevant witnesses. Accordingly, defendant respectfully requests that the Court enlarge by 56 days, from March 30, 2007, to and including May 25, 2007, the deadline for fact discovery. Defendant also respectfully requests that the Court enlarge the corresponding deadline for filing the joint status report at the conclusion of fact discovery from April 13, 2007, to and including June 8, 2007.

Case 1:06-cv-00101-FMA

Document 15

Filed 03/19/2007

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Donald E. Kinner DONALD E. KINNER Assistant Director

OF COUNSEL DONALD HARRIS Office of Counsel Army Corps of Engineers Room 1837 26th Federal Plaza New York, NY 10278

s/ Tara J. Kilfoyle TARA J. KILFOYLE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street Washington, D.C. 20530 tel: (202) 305-1709 fax: (202) 307-0972 Attorneys for Defendant

March 19, 2007

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Case 1:06-cv-00101-FMA

Document 15

Filed 03/19/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on March 19, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO COMPLETE DISCOVERY" 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/ Tara J. Kilfoyle