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

Case 1:05-cv-00612-CCM

Document 27

Filed 01/25/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) ) ) Plaintiff, ) ) v. ) ) ) THE UNITED STATES, ) ) Defendant. ) __________________________________________) SUSAN CARSON,

No. 05-612C (Judge Block)

JOINT MOTION FOR EXTENSION OF FACT DISCOVERY Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, the parties respectfully request that the Court enlarge by 30 days, to and including March 7, 2007, the deadline for discovery in the above-captioned matter. Fact discovery is currently scheduled to conclude on February 5, 2007. The parties have propounded and responded to written discovery requests. However, as part of plaintiff's request for documents, plaintiff requested documents that are protected by the Privacy Act. Accordingly, the parties filed a joint motion for a protective order, which the Court granted on December 11, 2006. Defendant intends to supplement its discovery responses. Due to the fact that many Government employees were out of the office at the end of December, counsel for defendant could not schedule a time to review the official personnel files of the other employees until January 18, 2007. Additional time will be needed to photocopy the relevant documents, to bates-number the relevant documents and label them as protected.

Case 1:05-cv-00612-CCM

Document 27

Filed 01/25/2007

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Although the parties intended to complete depositions in January 2007, the parties agreed to postpone the remaining depositions until after defendant provided plaintiff with supplemental discovery responses. The parties anticipate that the defendant will provide the supplemental discovery responses by end of January 2007, and that the parties will be able schedule the remaining depositions for February 2007. The parties, therefore, respectfully request that the Court extend the discovery deadline by 30 days, to and including March 7, 2007. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director

s/ Camilla C. McKinney CAMILLA C. MCKINNEY Law Offices of Camilla C. McKinney 1100 Fifteenth St., N.W. Suite 300 Washington, D.C. 20005 Tel: (202) 861-2934 Fax: (202) 517-9111 Attorney for Plaintiff

s/ Nancy M. Kim NANCY M. KIM Trial Attorney Department of Justice Civil Division Commercial Litigation Branch 1100 L Street, N.W. Attn: Classification Unit, 8th Floor Washington, D.C. 20530 Tel: (202) 353­0546 Fax: (202) 514-8640 Attorneys for Defendant

January 25, 2007

Case 1:05-cv-00612-CCM

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Filed 01/25/2007

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CERTIFICATE OF FILING I hereby certify that on January 25, 2007, a copy of the foregoing "JOINT MOTION FOR EXTENSION OF FACT DISCOVERY" was filed electronically. I understand that notice of this filing will be sent to all parties electronically via the CMECF system and that the parties may access this filing through the Court's electronic filing system.

s/ Nancy M. Kim