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

Case 1:05-cv-01121-EJD

Document 25

Filed 07/16/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ : WEST COAST CONTRACTORS OF : NEVADA, INC. : : Plaintiff, : : vs. : No. 05-1121C : (Chief Judge Damich) THE UNITED STATES : : Defendant. : ____________________________________: PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, plaintiff respectfully requests an enlargement of 8 days, from July 17, 2007 to July 25, 2007, to complete fact discovery. Plaintiff further requests that all subsequent deadlines be enlarged. Thus, plaintiff requests that the date for submission of expert reports by enlarged from July 24, 2007 to August 3, 2007. Plaintiff requests that the date for completion of expert depositions be enlarged from September 10, 2007 to September 18, 2007. Plaintiff requests that the dispositive motion deadline be enlarged from September 24, 2007 to October 19, 2007. Plaintiff's counsel has communicated with Michael N. O'Connell, attorney for defendant, who does not oppose this motion. In support of this motion, plaintiff states that plaintiff and defendant have agreed upon the following dates to take the remaining fact depositions in this case: July 24, 2007 July 24, 2007 July 25, 2007 Sharon Topping Kathryn Volpe Daniel Wong

Case 1:05-cv-01121-EJD

Document 25

Filed 07/16/2007

Page 2 of 3

This brief extension is necessary to accommodate the schedules of the foregoing witnesses, all of whom are retired from the United States Navy and live in the San Francisco, California area, and the respective schedules of counsel, who will be traveling to San Francisco to conduct these depositions. Accordingly, plaintiff respectfully requests that the Court grant this motion and revise the discovery schedule with the dates set forth above. Respectfully submitted, SHULMAN, ROGERS, GANDAL, PORDY & ECKER, P.A.

By:__________________________________ William C. Davis, III 11921 Rockville Pike, Suite 300 Rockville, Maryland 20852 (301) 230-5217 (301) 230-2891 (fax) Attorneys for Plaintiff West Coast Contractors of Nevada, Inc.

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Case 1:05-cv-01121-EJD

Document 25

Filed 07/16/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 16th day of July, 2007 a copy of the foregoing Plaintiff's Unopposed Motion for an Enlargement of Time was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

_____________________________________ William C. Davis, III
G:\39\West Coast\Documents\Unopposed Motion for Enlargement.7.16.07.wpd

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