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

Case 1:05-cv-00448-NBF

Document 69

Filed 03/24/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ______________________________________ ) RAYTHEON COMPANY, ) ) Plaintiff, ) ) v. ) No. 05-448C ) Judge Firestone UNITED STATES OF AMERICA, ) ) Defendant. ) ______________________________________ ) PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF THE EXPERT WITNESS DISCOVERY SCHEDULE TO CONDUCT EXPERT DEPOSITIONS Pursuant to Rule 6.1 of the Rules of this Court, Plaintiff Raytheon Company ("Raytheon"), respectfully requests an enlargement of time within which to conduct expert depositions. The requested enlargement would enlarge the time to complete such expert discovery as follows (for the Court's convenience, the current dates are set forth in brackets next to the requested dates): May 30, 2008 [March 28, 2008]: June 13, 2008 [April 11, 2008]: Close of expert discovery Joint status report regarding the next steps in the litigation due

This is Raytheon's third request for enlargement of time within which to complete expert witness discovery and first request for enlargement of time to conduct expert depositions. Raytheon requests this enlargement for the reasons set forth below. The parties have agreed upon May 29 and May 30, 2008 as the dates for conducting the depositions of Steven Vernon and Colin England, who have been identified as expert witnesses by Raytheon and Defendant, respectively. In this regard, an enlargement of the expert discovery schedule is necessary to conduct such expert witnesses depositions. Plaintiff's counsel has

Case 1:05-cv-00448-NBF

Document 69

Filed 03/24/2008

Page 2 of 3

discussed this motion with Defendant's counsel, C. Coleman Bird, Esq., and Defendant does not oppose this motion. Furthermore, Defendant consents to the proposed dates set forth above. For these reasons, Plaintiff Raytheon Company requests that the Court grant its motion for enlargement of the expert witness discovery schedule to conduct expert witness depositions.

Respectfully submitted,

Date: March 24, 2008

s/Karen L. Manos_________ Karen L. Manos, Esq. GIBSON, DUNN & CRUTCHER LLP 1050 Connecticut Avenue, NW Washington, DC 20036 Telephone: (202) 955-8536 Facsimile: (202) 530-9533 [email protected] Attorney of Record for Plaintiff RAYTHEON COMPANY

Of Counsel: Christyne K. Brennan, Esq. GIBSON, DUNN & CRUTCHER LLP

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Case 1:05-cv-00448-NBF

Document 69

Filed 03/24/2008

Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on the 24th day of March, 2008, a copy of the foregoing Plaintiff's Unopposed Motion for Enlargement of Expert Witness Discovery Schedule to Conduct Expert Depositions 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/Christyne K. Brennan_________ Christyne K. Brennan

100415810_1.DOC

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