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

Case 1:05-cv-01226-LAS

Document 18

Filed 05/08/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________ No. 05-1226 T (Judge Loren A. Smith) SUSAN M. ROHDE, Plaintiffs v. THE UNITED STATES, Defendant __________ JOINT MOTION FOR ENLARGEMENT OF TIME __________

Pursuant to RCFC 6.1, the parties respectfully move for an enlargement of time of sixtytwo days from May 29, 2007, to and including July 30, 2007, within which to complete discovery in this case. This is the third enlargement of time requested for this purpose, the first two enlargements of time having been granted for a total of two hundred ten days. In support of this motion, the parties state as follows: Counsel for the parties have engaged in extensive settlement discussions with respect to a draft settlement proposal which plaintiff has submitted. In connection with the draft settlement proposal, the parties have cooperatively conducted informal discovery. Therefore, the parties request additional time to complete any formal discovery that may be necessary in this action.

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Case 1:05-cv-01226-LAS

Document 18

Filed 05/08/2007

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This enlargement of time is requested in order to allow the parties additional time to complete all settlement negotiations and to attempt to narrow the scope of any additional discovery. WHEREFORE, the parties request that their motion be granted and that the scheduling order be revised as follows: 1. Discovery is to be completed by July 30, 2007. 2. Within 30 days following the close of discovery, the parties shall file a joint status report respecting proposed further proceedings in this case.

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Case 1:05-cv-01226-LAS

Document 18

Filed 05/08/2007

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Respectfully submitted,

5/8/2007 Date

s/John P. James JOHN P. JAMES, ESQUIRE 2000 IDS Center 80 South 8th Street Minneapolis, MN 55402 (612) 339-8131 Attorney for Plaintiff

5/8/2007 Date

s/Jennifer Dover Spriggs JENNIFER DOVER SPRIGGS Attorney of Record U.S. Department of Justice Tax Division Court of Federal Claims Section Post Office Box 26 Ben Franklin Post Office Washington, D.C. 20044 (202) 307-0840 EILEEN J. O'CONNOR Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section STEVEN I. FRAHM Assistant Chief

5/8/2007 Date

s/Steven I. Frahm Of Counsel Attorneys for Defendant