Free Proposed Pretrial Order - District Court of Federal Claims - federal

Case 1:05-cv-00297-LSM

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS STERLING, WINCHESTER & LONG, L.L.C., Plaintiff, v. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) )

No. 05-297C (Senior Judge Margolis)

JOINT PROPOSED SCHEDULING ORDER In accordance with the parties' Status Conference with the Court on October 11, 2005, the parties submit the following proposed schedule for the completion of discovery in this case: 1. The parties will exchange their initial disclosures pursuant to RCFC 26(a) on or before October 21, 2005. 2. 3. The parties will voluntarily exchange documents until November 15, 2005. The parties will engage in additional fact discovery from November 15, 2005, through May 26, 2005. 4. Expert discovery will commence on April 14, 2006. Plaintiff will identify its expert witness(es) on or before April 14, 2006. 5. On or before May 12, 2006, the plaintiff will submit to the defendant all expert reports in the manner and form required by Rule 26(a)(2), including all supporting documentation, spreadsheets, calculations, and formulas supporting damages calculations and spreadsheets, in hard copy and electronically; iterations of prior drafts need not be submitted. 6. 7. The defendant will identify its expert witness(es) on or before June 9, 2006. On or before August 3, 2006, the defendant will submit to the plaintiff all expert

Case 1:05-cv-00297-LSM

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reports in the manner and form required by Rule 26(a)(2), including all supporting documentation, spreadsheets, calculations, and formulas supporting damages calculations and spreadsheets, in hard copy and electronically; iterations of prior drafts need not be submitted. 8. 9. The parties will conclude expert discovery on or before October 16, 2006. The parties will file a joint status report with the Court proposing further proceedings on or before October 24, 2006. Respectfully submitted,

PETER D. KEISLER Assistant Attorney General

/s/ David M. Cohen by James M. Kinsella DAVID M. COHEN Director

/s/ Frederick L. Wright FREDERICK L. WRIGHT Vaughn, Wright & Stearns LLP One Paces West ­ Suite 1740 2727 Paces Ferry Road, N.W. Atlanta, GA 30339 Tele: (770) 805-9889 Facsimile: (770) 805-9191 Attorney for Plaintiff DATE: 10/13/05

/s/ Sheryl L. Floyd SHERYL L. FLOYD Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 307-0282 Facsimile: (202) 514-8624

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OF COUNSEL: CHRISTOPHER BURTON United States Postal Service 475 L'Enfant Plaza, S.W., Washington, DC 20260 Attorneys for Defendant DATE: 10/13/05

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CERTIFICATE OF FILING I hereby certify that on 14th day of OCTOBER, 2005, a copy of the "JOINT PROPOSED SCHEDULING ORDER" 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/ Sheryl L. Floyd