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

Case 1:05-cv-00462-LMB

Document 16

Filed 06/20/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

DICK PACIFIC/GHEMM, JV, On behalf of W. A. Botting Company, Plaintiff v.

THE UNITED STATES Defendant

) ) ) ) ) ) ) ) )

No. 05-462C (Judge Baskir)

JOINT MOTION TO EXTEND DISCOVERY AND TIME TO FILE JOINT STATUS REPORT The parties respectfully request that the Court extend the discovery deadline by 31 calendar days, up to and including July 31, 2006. The parties have engaged in extensive discovery in the above captioned case, including the exchange of interrogatories and requests for the production of documents, and several depositions in both Alaska and Washington state. Several outstanding document requests and scheduling issues, however, require the parties to request additional time to complete the remaining depositions, which tentatively have been scheduled for the week of July 17, 2006, pending this Court's Order.

Case 1:05-cv-00462-LMB

Document 16

Filed 06/20/2006

Page 2 of 3

The parties further respectfully request leave to file a joint status report with the Court on July 31, 2006, proposing either dispositive motions and a preliminary briefing schedule, or a trial date and proposed schedule, and indicating whether the parties wish to pursue Alternative Dispute Resolution. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director /s/ Robert H. Crick ROBERT H. CRICK Winston & Cashatt, Lawyers 601 West Riverside Avenue 1900 Seafirst Financial Center Spokane, WA 99201-0695 /s/ Steven M. Mager STEVEN M. MAGER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, NW Washington, D.C. 20530 Tele: (202) 616-2377 [email protected] Attorneys for Defendant June 20, 2006 -2-

Attorney for Plaintiff June 20, 2006

Case 1:05-cv-00462-LMB

Document 16

Filed 06/20/2006

Page 3 of 3

CERTIFICATE OF FILING/SERVICE I hereby certify that on this 20th day of June, 2006, a copy of the foregoing "JOINT MOTION TO EXTEND DISCOVERY AND TIME TO FILE JOINT STATUS REPORT" 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. Parties may access this filing through the Court's system.

/s/ Steven M. Mager Steven M. Mager Trial Attorney Commercial Litigation Branch Civil Division Department of Justice