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

Case 1:05-cv-00463-LAS

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Filed 04/28/2006

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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 155 calendar days, to and including September 30, 2006, within which to complete discovery in this case. The parties are presently scheduled to complete This is either party's

discovery on or before April 28, 2006.

first 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. The additional time is necessary because counsel for the parties have begun, but not yet completed discovery. Specifically, defendant has initiated an audit of plaintiff's claims, and expects to issue discovery requests based 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 expect that Thus, the

depositions will take place in July and August, 2006.

Case 1:05-cv-00463-LAS

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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. Dated: this 28th day of April 2005.

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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CERTIFICATE OF ELECTRONIC FILING I hereby certify that on the 28th day of APRIL, 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