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

Case 1:05-cv-00183-NBF

Document 15

Filed 12/29/2005

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

THE UNITED STATES, Defendant.

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of two months, to and including February 28, 2006, for the parties to conclude discovery. Discovery is presently set to end on December 31, 2005. Government counsel has discussed this motion with plaintiff's counsel and represents that plaintiff does not oppose it. The additional time is requested to allow for depositions of employees of the plaintiff. The Government served its interrogatories and requests for production of documents upon plaintiff in September 2005, expecting that timely responses thereto would permit depositions to occur in November and early December. Plaintiff, however, needed additional time to respond to these discovery requests and did not provide a response to Government counsel until midDecember. Because of the holidays and previously planned travel for other cases, Government counsel will not likely be able to depose the relevant employees of plaintiff until February, 2006. For the foregoing reasons, defendant respectfully requests that the Court grant this unopposed motion for an enlargement of time. Respectfully Submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-00183-NBF

Document 15

Filed 12/29/2005

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 December 29, 2005 Attorneys for Defendant

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