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

Case 1:06-cv-00101-FMA

Document 13

Filed 01/26/2007

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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)

JOINT MOTION FOR AN ENLARGEMENT OF TIME TO COMPLETE DISCOVERY Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, the parties respectfully request that the Court enlarge by 58 days, through March 30, 2007, the deadline for the parties to complete discovery. Currently, discovery is scheduled to end on January 31, 2007. This is the parties' first such request. The parties are currently engaged in written discovery. However, the parties have experienced delays resulting from difficulties in the retrieval of requested electronic data and the need to copy a large number of oversized survey maps in accordance with Government Printing Office procurement regulations. In addition, because a substantial number of documents were requested and produced during discovery, the parties need additional time to review discovery responses, to schedule depositions of relevant witnesses, and take additional discovery, as necessary. If difficulties retrieving and reviewing electronic data persist, it is possible that the parities will need to request a second enlargement of time to complete discovery. However, at this juncture, the parties believe that a 58 day extension will be sufficient. Accordingly, we

Case 1:06-cv-00101-FMA

Document 13

Filed 01/26/2007

Page 2 of 3

respectfully request that the Court enlarge by 58 days, from January 31, 2007, to and including March 30, 2007, the deadline for fact discovery. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Donald E. Kinner DONALD E. KINNER Assistant Director

s/ Michael Payne MICHAEL PAYNE Payne Hackenbracht & Sullivan 220 Commerce Dr., Suite 100 Fort Washington, PA 19034 tel: (215) 542-2777 fax: (215) 542-277 Attorney for plaintiff

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

January 26, 2007

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Case 1:06-cv-00101-FMA

Document 13

Filed 01/26/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on January 26, 2007, a copy of the foregoing "JOINT 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