Free Response - District Court of Federal Claims - federal

Case 1:05-cv-00170-LAS

Document 29

Filed 04/19/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS SWANSON GROUP, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

Case No. 05-170C consolidated with 05-171C (Senior Judge Loren A. Smith)

PLAINTIFF'S UNOPPOSED CLARIFICATION OF PARAGARPH 3 OF THE JOINT PROPOSED AMENDED PRE-TRIAL SCHEDULE FILED APRIL 18, 2006 Plaintiff submits the following clarification as to the parties' intent with respect to paragraph 3 of the Joint Proposed Amended Pre-Trial Schedule filed by defendant on April 18, 2006. Defendant's counsel has been informed of this clarification and defendant does not oppose it.

Paragraph 3 of the Joint Proposed Amended Pre-Trial Schedule currently states: "The parties shall have an additional 90 days, or until August 11, 2006 to complete written discovery on the issue of liability." It was the parties' intent that each party should have until August 11, 2006 to complete all discovery on the issue of liability, including deposition discovery, with the exception of the possible depositions of designated experts referenced in paragraphs 4, 5 and 6 of the Joint Proposed Amended Pre-Trial Schedule.

1

Case 1:05-cv-00170-LAS

Document 29

Filed 04/19/2006

Page 2 of 2

Respectfully submitted, s/Gary G. Stevens SALTMAN & STEVENS P.C. 1801 K Street, N.W. Suite M110 Washington, D.C. 20006 (202) 452-2140 Counsel for Plaintiff Dated: April 19, 2006

2