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

Case 1:05-cv-01226-LAS

Document 15

Filed 02/21/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________ No. 05-1226 T (Judge Loren A. Smith) SUSAN M. RHODE, 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 ninety days from February 28, 2007, to and including May 29, 2007, within which to complete discovery in this case. This is the second enlargement of time requested for this purpose, the first enlargement of time having been granted for a total of one hundred twenty days. In support of this motion, the parties state as follows: Counsel for the parties have consulted about an overall plan for the completion of all remaining discovery in the instant action. Based upon that discussion, it was determined that additional time is needed in order to complete discovery in this action. Once discovery is complete, the parties will be able to conclude settlement discussions and to advise the Court with respect to further proceedings.

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Case 1:05-cv-01226-LAS

Document 15

Filed 02/21/2007

Page 2 of 3

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 May 29, 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. 3. The telephonic status conference currently scheduled for April 17, 2007, shall be rescheduled to June 27, 28, or 29, 2007, at 3:30 p.m. (EST).

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Case 1:05-cv-01226-LAS

Document 15

Filed 02/21/2007

Page 3 of 3

Respectfully submitted,

2/21/07 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

2/21/07 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

2/21/07 Date

s/Steven I. Frahm Of Counsel Attorneys for Defendant