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

Case 1:05-cv-00170-LAS

Document 28

Filed 04/18/2006

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 Smith)

JOINT PROPOSED AMENDED PRE-TRIAL SCHEDULE Pursuant to the United States's motion for enlargement of time, filed simultaneously herewith, the United States submits the following proposed amended pre-trial schedule to allow new counsel for the government adequate time to prepare the government's case: 1. Initial disclosures on the issue of liability were made by the parties on December 20, 2005. The United States responded to plaintiff's written discovery on the issue of liability on January 12, 2006. The parties shall have an additional 90 days, or until August 11, 2006 to complete written discovery on the issue of liability. The parties shall designate experts and exchange expert reports on the issue of liability by September 7, 2006. The parties shall designate rebuttal experts and exchange rebuttal reports on the issue of liability by October 7, 2006. The parties shall depose all experts by November 7, 2006. The parties shall file dispositive motions, if any, no later than December 5, 2006. After the resolution of all dispositive motions, the parties shall contact the Court to schedule a pre-trial conference. 1

2.

3.

4.

5.

6. 7. 8.

Case 1:05-cv-00170-LAS

Document 28

Filed 04/18/2006

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

PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director OF COUNSEL: MARCUS R. WAH Associate Regional Attorney USDA-OGC, Pacific Region s/Joan M. Stentiford JOAN M. STENTIFORD Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Phone: (202) 616-0341 Fax: (202) 514-8624 Counsel for Defendant

April 17, 2006

2