Free Motion to Amend Schedule - District Court of Federal Claims - federal

Case 1:05-cv-00457-LJB

Document 17

Filed 01/31/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS GEE & JENSEN ENGINEERS, ARCHITECTS AND PLANNERS, Plaintiff, vs. UNITED STATES OF AMERICA, DEPARTMENT OF THE NAVY, Defendant. ) ) ) ) ) ) ) ) ) ) ) )

Case Number: 1:05-cv-00457-LJB

PLAINTIFF'S UNOPPOSED MOTION FOR AN EXTENSION OF TIME TO COMPLETE DISCOVERY Pursuant to Rule 6(b)(1) and 6.1 of the United States Court of Federal Claims, the parties respectfully request that the Court modify the October 23, 2006 scheduling order to enlarge the period provided for producing expert reports from February 1, 2007 to and including February 12, 2007 and to extend the close of the fact discovery period from March 1, 2007 to May 4, 2007. This is the parties third motion for an enlargement of time for this purpose. Counsel for the Defendant does not oppose this motion. The parties have been continuing to work together to complete discovery, documents have been exchanged, and the parties have met to discuss resolution of this case, including possible bases for settlement. Additional time is requested to continue discussions and schedule depositions of fact and expert witnesses. As a result, the parties are filing this motion jointly and respectfully request that the Court modify the October 23, 2006 scheduling order as follows: 1. Disclosure of expert reports and related material pursuant to Rule 26(a)(2) of the Rules of Court of Federal Claims shall take place on or before February 12, 2007;

Case 1:05-cv-00457-LJB

Document 17

Filed 01/31/2007

Page 2 of 2

2. 3.

Fact discovery will close on May 4, 2007; and No later than May 15, 2007, the parties will file a joint status report. PEDERSEN & SCOTT, P.C.

S/William A. Scott William A. Scott 775 St. Andrews Blvd. Charleston, SC 29412 (843) 556-5656 ATTORNEY FOR PLAINTIFF

Dated this

31th

day of January , 2007.