Free Motion to Compel - District Court of Federal Claims - federal

Page 1 of 2 Case 1:05-cv-01209-LMB Jane Sorey
From: Sent: To: Rebecca E. Crandall Wednesday, July 11, 2007 3:35 PM Valerie J. Swanson; Jane Sorey

Document 72-3

Filed 08/02/2007

Page 1 of 2

Exhibit B

Subject: FW: Jennings - discovery issues

Rebecca Crandall [email protected] From: Jim Ward [mailto:[email protected]] Sent: Wednesday, July 11, 2007 3:27 PM To: Rebecca E. Crandall Subject: RE: Jennings - discovery issues Of course he cannot communicate with my client Obviously, the email was sent to him by mistake. I have no clue what you are talking about as to these times. Why make this all so hard? If you want to reply to our response and also reply to the motion, do it all at once if you want. It matters not to me if the date is July 23 or 26. You decide. I do not have the luxury of three lawyers working on this case as you do. I will have your response this week. Thanks James S. Ward WARD & WILSON, L.L.C. 2100 Southbridge Parkway Suite 580 Birmingham, Alabama 35209 Phone: 205-871-5404 Fax: 205-871-5758 [email protected]

From: Rebecca E. Crandall [mailto:[email protected]] Sent: Wednesday, July 11, 2007 2:15 PM To: Jim Ward Cc: Jane Sorey Subject: Jennings - discovery issues You filed a combination response to a motion and a new motion. The way you filed it using the CM/ECF system, it gave us a deadline based on a reply ­ so July 23 I believe. I think we can address both together as you have done, but we'd prefer to have until a response to a motion would be due ­ July 26 I think. Ordinarily it would not be a problem to respond by the earlier date, but Tony is out of the office July 13-24. Would you consent to us filing a request for enlargement of time to respond so that we have until July 26? When do you expect to have Ready Built's discovery responses to Rogs 17 -19, RPDs 29-34 & RFAs 15-57? They were due June 27. Ready Built's responses to these might help to narrow the remaining discovery issues. When will Ready Built produce the documents and things promised in your June 27 letter? Also ­ your client emailed Tony regarding Jennings' discovery requests. Tony is still waiting to hear from you as to whether he may communicate with your client. Feel free to give me a call if you would like to discuss any of these issues. Rebecca Crandall [email protected] From: Jim Ward [mailto:[email protected]]

8/2/2007

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Sent: Wednesday, July 11, 2007 2:58 PM To: Rebecca E. Crandall Subject: what is the confusion on the date? James S. Ward WARD & WILSON, L.L.C. 2100 Southbridge Parkway Suite 580 Birmingham, Alabama 35209 Phone: 205-871-5404 Fax: 205-871-5758 [email protected]

Case 1:05-cv-01209-LMB

Document 72-3

Filed 08/02/2007

Page 2 of 2

8/2/2007