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

Case 1:05-cv-01209-LMB

Document 32

Filed 11/08/2006

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THE UNITED STATES COURT OF FEDERAL CLAIMS JENNINGS TRANSMISSION SERVICE OF GOLDSBORO, INC., PLAINTIFF, v. THE UNITED STATES, DEFENDANT. ) ) ) ) ) ) ) ) ) )

CASE NO. 1:05-cv-1209 LMB

JASPER ENGINE'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DISCOVERY REQUESTS Third-Party Defendant Jasper Engines & Transmissions ("Jasper Engines"), by counsel, respectfully requests an extension of time within which to respond to Plaintiff Jennings Transmission Service of Goldsboro, Inc.'s ("Jennings") First Set of Interrogatory Nos. 1-10 and Requests for Production of Documents 1-19 (hereinafter "Discovery Requests"). In support of this motion, Jasper Engines states as follows: 1. Jennings served its Discovery Requests to Jasper Engines on or about October 25,

2006. Accordingly, Jasper Engines' responses are not due until November 24, 2006. This date has not yet passed. 2. The Discovery Requests are fairly extensive and broad. It is presently believed, in

good faith, that preparation of Jasper Engines' response to the Discovery Requests will require Jasper Engines and its counsel to review a significant amount of documents. Jasper Engines has diligently initiated the initial steps for conducting that review. However, Jasper Engines will need more time - at least thirty (30) more days - to prepare its initial written responses.

Case 1:05-cv-01209-LMB

Document 32

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3.

Jasper Engines' counsel has conferred with Jennings' counsel, Larry Coats, about

this motion and is authorized to report that Jennings' counsel has no objection to the requested thirty (30) day extension of time. 4. This motion is not being made in bad faith and/or for purposes of delay.

WHEREFORE, Third-Party Defendant Jasper Engines & Transmissions, by counsel, respectfully requests an extension of time to and including December 24, 2006, within which to respond to the Jennings' First Set of Interrogatory Nos. 1-10 and Requests for Production of Documents 1-19, and for all other relief that is appropriate under the circumstances. 1. Respectfully submitted,

s/ James M. Hinshaw James M. Hinshaw Rafael A. Sanchez Bingham McHale LLP 2700 Market Tower 10 W. Market Street Indianapolis, IN 46204-4900 (317) 635-8900 Attorneys for Jasper Engines & Transmissions

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Case 1:05-cv-01209-LMB

Document 32

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CERTIFICATE OF SERVICE The undersigned hereby certifies that on November 8, 2006, a true and correct copy of the above and foregoing document was filed electronically. Notice of this filing will be sent to the following parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system: Larry L. Coats Coats & Bennett PLLC 1400 Crescent Green, Suite 300 Cary, NC 27511 [email protected] Ken B. Barrett U.S. Department of Justice Civil Div. ­ Commercial Litigation Br. 1100 L Street, NW, 8th Floor Washington, DC 20530 [email protected] James S. Ward Ward & Wilson, LLC 2100 Southbridge Parkway, Suite 850 Birmingham, AL 35209 [email protected] s/ James M. Hinshaw

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