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

Case 1:05-cv-00993-LB

Document 11

Filed 09/26/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TRITON MARINE CONSTRUCTION CORPORATION, Plaintiff, vs. UNITED STATES OF AMERICA, Defendant No. 05-993 C Judge Lawrence J. Block

JOINT REQUEST FOR ENLARGEMENT OF TIME The parties jointly come before the court with an unopposed request for an enlargement of time in which to (1) complete fact discovery, (2) disclose the identity of any experts, (3) complete expert witness discovery, and (4) file a joint status report. The parties make this joint request because they have entered into preliminary settlement discussions which will require input and analysis from both sides. To this end, a settlement offer has been made with a deadline of October 6, 2006. The fact discovery cutoff is October 2, 2006. In light of the foregoing, the parties jointly request additional time to properly investigate the possibility of settlement without the expense of litigation. The February 7, 2006, Scheduling Order deadlines are as follows: 1. 2. 3. Complete fact discovery by 10/2/06 ­ requested deadline 2/6/07 Disclose the identity of any experts by 10/16/06 ­ requested deadline 2/23/07 Complete expert witness discovery by 11/17/06 ­ requested deadline 3/30/07

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Case 1:05-cv-00993-LB

Document 11

Filed 09/26/2006

Page 2 of 2

4.

File a joint status report by 12/1/06 ­ requested deadline 4/13/07

Due to ongoing settlement discussions, the parties have agreed to, and jointly request, a four month extension of all of the above deadlines. Dated: September 26, 2006. Respectfully submitted, s/ Stephen L. Nourse STEPHEN L. NOURSE CARNEY BADLEY SPELLMAN, P.S. 701 Fifth Avenue, Suite 3600 Seattle, WA 98104-7010 (206) 622-8020 Email: [email protected] Attorneys for Triton Marine Construction Corporation Of Counsel: JOHN C. DIPPOLD CARNEY BADLEY SPELLMAN, P.S. 701 Fifth Avenue, Suite 3600 Seattle, WA 98104-5017 (206) 622-8020 Email: [email protected] Attorneys for Triton Marine Construction Corporation PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Deborah A. Bynum DEBORAH A. BYNUM Assistant Director s/ Elizabeth Thomas ELIZABETH THOMAS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 (202) 353-4175 Email: [email protected] Attorneys for Defendant

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