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

Case 1:05-cv-00448-NBF

Document 56

Filed 08/06/2007

Page 1 of 3

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
EXPERT WITNESS DISCOVERY SCHEDULE

Pursuant to Rule 6.1 of the Rules of this Cour, 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 Cour's convenience, the curent dates are set forth in brackets next
to the requested dates):
September 17, 2007 (August 13, 2007): Deadline for submission of rebuttal expert reports
October 16, 2007 (September 14,2007): Deadline for submission of

replies to rebuttal expert
reports

November 20,2007 (October 12,2007): Close of expert discovery

December 4, 2007 (October 26,2007): Joint status report regarding the next steps in the
litigation due
This is Raytheon's first request for enlargement of

time within which to complete expert witness

discovery, and Raytheon requests this enlargement for the reasons set forth below.
Plaintiff

received Defendant's expert report on or about July 2, 2007. In this report,

Defendant's expert, Colin England, FSA, EA, primarily contends that additional information is

necessary to his analysis and raises actuarial questions regarding Plaintiffs segment calculations.

Case 1:05-cv-00448-NBF

Document 56

Filed 08/06/2007

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Plaintiff requests this enlargement of time so that it may collect certain additional information

that Defendant's expert has requested and so that Plaintiffs expert may fully respond to the

questions raised in Defendant's expert report. Plaintiffs counsel has discussed this motion with
Defendant's counsel, C. Coleman Bird, Esq., and Defendant does not oppose this motion.

Furhermore, Defendant consents to the proposed dates set forth above.
For these reasons, Plaintiff

Raytheon Company requests that the Cour grant its motion

for enlargement of time to complete expert witness discovery.

Respectfully submitted,

Date: August 6, 2007

sf Karen L. Manos Karen L. Manos, Esq.

GIBSON, DUN & CRUTCHER LLP 1050 Connecticut Avenue, NW Washington, DC 20036 Telephone: (202) 955-8536
Facsimile: (202) 530-9533 kmanoS(fgibsondunn.com

Attorney of Record for Plaintiff RA YTHEON COMPANY
Of Counsel:

Christyne K. Brennan, Esq.

GIBSON, DUN & CRUTCHER LLP

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Case 1:05-cv-00448-NBF

Document 56

Filed 08/06/2007

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CERTIFICATE OF SERVICE

I hereby certify that on the 6th day of August, 2007, a copy of

the foregoing
Expert Witness Discovery Schedule was fied

Plaintiffs Unopposed Motion for Enlargement of

electronically. I understand that notice of

this fiing will be sent to all parties by operation of

the

Cour's electronic filing system. Paries may access this fiing through the Cour's system.

sfChrstyne K. Brennan Christyne K. Brennan

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