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

Case 1:05-cv-00463-LAS

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Filed 10/12/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GOVERNMENT TELECOMMUNICATIONS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) No. 05-463C )(Senior Judge Smith) ) ) ) )

PLAINTIFF'S MOTION FOR AN ENLARGEMENT OF TIME, _ UPON BEHALF OF BOTH PARTIES_________ Plaintiff, upon behalf of both parties, respectfully requests an enlargement of time of 151 calendar days, to and including February 28, 2007, within which to complete discovery in this case. The parties are presently scheduled to complete This is either

discovery on or before September 30, 2006.

party's second request for an enlargement of time for this purpose. Counsel for plaintiff has contacted counsel for

defendant regarding this motion; she has stated that defendant concurs in this motion. Counsel for plaintiff has been traveling

on client business for much of the intervening two weeks since the passing of the September 30, 2006 discovery cut-off date and counsel for defendant, for at least part of that time, has been in trial. The additional time is necessary because counsel for the parties have begun, but not yet completed discovery. Specifically, defendant has recently concluded an audit of plaintiff's claims, and expects to issue discovery requests based

Case 1:05-cv-00463-LAS

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partly upon the findings contained in the audit report.

The

parties expect that they will conduct depositions based upon responses to their respective discovery requests. The parties Thus,

expect that depositions will take place in January 2007.

the additional time is necessary within which to conduct and complete discovery in this case. For the foregoing reasons, we respectfully request that our motion for an enlargement of time, upon behalf of both parties, be granted. In connection with this request, the parties also request that the Status Conference scheduled for October 18, 2006 be postponed, as well. Dated: this 12th day of October 2006.

Respectfully submitted, Government Telecommunications, Inc. By Counsel: /s/ John C. Person John C. Person, Esquire PERSON & CRAVER LLP 1801 K Street, N.W. Washington, D.C. 20006 (202) 466-4434 ­ phone (202) 466-4416 ­ fax [email protected] Attorneys for Plaintiff

Case 1:05-cv-00463-LAS

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Filed 10/12/2006

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CERTIFICATE OF ELECTRONIC FILING I hereby certify that on the 12th day of October 2006, a copy of the foregoing "PLAINTIFF'S MOTION FOR AN ENLARGEMENT OF TIME, UPON BEHALF OF BOTH PARTIES" 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, and that the parties may access this filing through the Court's system. /s/ John C. Person