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

Case 1:05-cv-00448-NBF

Document 58

Filed 09/13/2007

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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 SECOND UNOPPOSED MOTION FOR ENLARGEMENT OF EXPERT WITNESS DISCOVERY SCHEDULE Pursuant to Rule 6.1 of the Rules of this Court, Plaintiff Raytheon Company ("Raytheon"), respectfully requests an enlargement of time within which to complete expert witness discovery. 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): November 16, 2007 [September 17, 2007]: Deadline for submission of rebuttal expert reports January 18, 2008 [October 16, 2007]: Deadline for submission of replies to rebuttal expert reports

February 22, 2008 [November 20, 2007]: Close of expert discovery March 7, 2008 [December 4, 2007]: Joint status report regarding the next steps in the litigation due

This is Raytheon's second request for enlargement of time within which to complete expert witness discovery, and Raytheon requests this enlargement for the reasons set forth below. Plaintiff's expert is continuing to diligently prepare its rebuttal expert report and requires this additional time to finalize its report. Plaintiff's counsel has discussed this motion with

Case 1:05-cv-00448-NBF

Document 58

Filed 09/13/2007

Page 2 of 3

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 time to complete expert witness discovery.

Respectfully submitted,

Date: September 13, 2007

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 58

Filed 09/13/2007

Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on the 13th day of September, 2007, a copy of the foregoing Plaintiff's Second Unopposed Motion for Enlargement of Expert Witness Discovery Schedule 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

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