Free Motion for Leave to File Out of Time - District Court of Federal Claims - federal

Case 1:05-cv-00448-NBF

Document 26-2

Filed 03/24/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS RAYTHEON COMPANY, Plaintiff, v. UNITED STATES OF AMERICA, Defendant ) ) ) ) ) ) ) ) )

No. 05-448C (Judge Firestone)

JOINT STATUS REPORT As directed by the Court's Order dated October 28, 2005, plaintiff, Raytheon Company, and defendant, the United States, jointly and respectfully submit the following joint status report. The parties have conferred, and propose the following schedule for the Court's consideration: October 13, 2006 December 8, 2006 Close of fact discovery Deadline for submission of expert reports, expert witness disclosures under RCFC 26(a)(2), and responses to written expert witness discovery requests Close of expert discovery Parties to file a joint status report regarding the next steps in the litigation

January 26, 2007 February 6, 2007

In addition, pursuant to RCFC 29, the parties have stipulated and agreed that (i) defendant shall serve its responses to Plaintiff's First Set of Interrogatories and Requests for Production of Documents, served by mail on February 16, 2006 and sent by electronic mail on February 21, 2006, on or before May 1, 2006, and (ii) plaintiff shall serve its responses to

Case 1:05-cv-00448-NBF

Document 26-2

Filed 03/24/2006

Page 2 of 3

Defendant's First Set of Interrogatories and Requests for Production of Documents, served by mail on February 24, 2006 and sent by facsimile that same day, on or before May 4, 2006. Respectfully submitted, s/ Karen L. Manos KAREN L. MANOS Gibson, Dunn & Crutcher, LLP 1050 Connecticut Avenue, N.W. Washington, D.C. 20036 (202) 955-8536 (Phone) (202) 530-9533 (Facsimile) Attorney for Plaintiff Raytheon Company Dated: March 24, 2006 s/ C. Coleman Bird C. COLEMAN BIRD Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Telephone: 202.307.0453 Facsimile: 202.514.7965 Attorneys for Defendant United States of America OF COUNSEL: LAWRENCE S. RABYNE Defense Contract Management Agency 1523 W. Central Road Arlington Heights, IL 60005-2451 PETER D. KEISLER Assistant Attorney General

DAVID M. COHEN Director

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Case 1:05-cv-00448-NBF

Document 26-2

Filed 03/24/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on the 24th day of March, 2006, a copy of the foregoing 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/ C. Coleman Bird