Free Motion to Take Deposition - District Court of Federal Claims - federal

Case 1:05-cv-00400-FMA

Document 62-5

Filed 12/05/2007

Page 1 of 1

Mr. Wolak, I intend to file this date a motion this AM entitled,

MOTION TO RE-OPEN DISCOVERY AS TO CLYDE THOMPSON, FREDERICK ISLER, SAM SNYDER, CAROLYN COOKSIE AND DR. JOHN SWIGER
I indend to attach the PDF file here attached to the motion as evidence of the need to further depose Ms. Cooksie. While I do have your denial letters on my in good faith requests to move discovery along in this case, they do not directly and expressly relate to the proposed instant motion. Please let me know the government's position on such a motion. If you are unable to get back to me by 11:30 AM EST, I intend to not the effort to confer. I will be in touch with you re a date fro Dr. Swiger's deposition in Texas. Please be prepared to pay Dr. Swiger in advance as he has requested in conversation with me. Thank you. I must say I am very disappointed in what appears to be a "significant change" in the government's prior demeanor regarding settlement in this case. I should not, given the proclivities of your client and its OGC Counsel, be surprised. Of well, that's what Courts are for. Myart

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