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

Case 1:05-cv-00183-NBF

Document 19

Filed 02/27/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS KAEPER MACHINE, INC., Plaintiff, v. ) ) ) ) No. 05-183C ) ) (Judge Firestone) ) ) ) )

THE UNITED STATES, Defendant.

DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of two months, to and including April 30, 2006, for the parties to conclude discovery. Discovery is presently set to end on February 28, 2006. Government counsel has attempted to contact counsel for plaintiff, but was unable to discuss this matter with him prior to filing this motion. The additional time is requested to allow for depositions of employees of the plaintiff. As the Court is aware, Mr. Oh, the owner of Euclid Machine, is confined at the Federal Correctional Institution at Elkton, Ohio. We have provided the warden of the prison with the Court's order authorizing Mr. Oh's deposition, but have not yet completed the logistical arrangements for the deposition. We anticipate scheduling of the deposition to be completed shortly. For the foregoing reasons, defendant respectfully requests that the Court grant this motion for an enlargement of time. Respectfully Submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-00183-NBF

Document 19

Filed 02/27/2006

Page 2 of 2

DAVID M. COHEN Director

s/James M. Kinsella JAMES M. KINSELLA Deputy Director

s/J. Reid Prouty J. REID PROUTY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7586 Fax: (202) 514-7969 February 27, 2006 Attorneys for Defendant

2