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

Case 1:05-cv-01226-LAS

Document 13

Filed 10/24/2006

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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 one hundred twenty days from October 31, 2006, to and including February 28, 2007, within which to complete discovery in this case. This is the first enlargement of time requested for this purpose. In support of this motion, the parties state as follows:

Plaintiff has submitted a draft settlement proposal in this action. The parties are currently engaged in settlement discussions and informal discovery in connection with the draft settlement proposal. The outcome of the parties' settlement discussions may serve to limit the scope of any additional discovery to be completed in this case. Thus, in an effort to secure an efficient and inexpensive determination in this matter, the parties request additional time to complete discovery in order to allow the parties time to finalize all settlement discussions.

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Case 1:05-cv-01226-LAS

Document 13

Filed 10/24/2006

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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 February 28, 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 December 3, 2006, shall be rescheduled to April 16, 17, or 18, 2007, at 3:30 p.m. (EST).

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Case 1:05-cv-01226-LAS

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Filed 10/24/2006

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Respectfully submitted,

10/24/06 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

10/24/06 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 Acting Chief, Court of Federal Claims Section STEVEN I. FRAHM Assistant Chief

10/24/06 Date

s/Steven I. Frahm Of Counsel Attorneys for Defendant

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Case 1:05-cv-01226-LAS

Document 13

Filed 10/24/2006

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