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

Case 1:05-cv-00675-MMS

Document 39

Filed 09/28/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS No. 05-675 T (Judge Margaret M. Sweeney) __________ WILLIAM F. AND THERESE HARTMAN, Plaintiffs v. UNITED STATES, Defendant

__________ JOINT MOTION FOR EXTENSION OF TIME _________

Pursuant to RCFC 6(b), defendant, the parties move this Court for an enlargement of 60 days, from September 30, 2007, to and including November 29, 2007, of the deadline for the parties to complete discovery in the above-captioned case. No prior enlargement of this deadline has been requested. The parties have conducted informal discovery, the plaintiff has served formal discovery on the defendant, which defendant responded to. The parties have scheduled the deposition of Cap Gemini on October 11, 2007, and the deposition of the plaintiff on October 16, 2007. The parties anticipate scheduling the depositions of Ernst and Young and Merrill Lynch in the same time period, but have not yet finalized the dates for those depositions. Once those depositions are completed, the parties anticipate there might be a need for some brief

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Case 1:05-cv-00675-MMS

Document 39

Filed 09/28/2007

Page 2 of 2

follow-up discovery. The enlargement sought by this motion will allow the parties time to complete the necessary discovery in this case. WHEREFORE, the parties respectfully request that the deadline for completing discovery be extended from September 30, 2007, to, and including, November 29, 2007.

Respectfully submitted, 9/28/07 DATE ___s/ Kenneth R. Boiarsky____ KENNETH R. BOIARSKY 174 Los Alamitos Lane HCR 74-22126 El Prado, New Mexico 87529-9540 (505) 737-5940 Counsel for Plaintiffs

9/28/07 DATE

___s/ Benjamin C. King, Jr.____ BENJAMIN C. KING, JR. Attorney of Record Justice Department (Tax) Court of Federal Claims Section Post Office Box 26 Ben Franklin Post Office Washington, D.C. 20044 (202) 307-6506 RICHARD T. MORRISON Acting Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section

9/28/07 DATE

_ s/ David Gustafson____________ Of Counsel Counsel for Defendant

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