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

Case 1:04-cv-00497-LMB

Document 57

Filed 09/26/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JANELLE HOHNKE, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 04-0497C (Judge Baskir)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, defendant respectfully requests a 28 day enlargement of time, from September 29, 2006 to October 29, 2006, to conduct fact discovery. Defendant has discussed this motion with counsel for Janelle Hohnke, who does not oppose this motion. This is defendant's first request for an enlargement of time for this purpose. In support of this motion, defendant states that it served written discovery requests upon plaintiff on August 18, 2006. Defendant needs the responses to these discovery requests before it deposes Ms. Hohnke. However, plaintiff's counsel has stated that she will not be able to provide the response to the discovery requests until October 11, 2006 because of the press of other matters, including a vacation from August 26 to September 4, 2006, two days of administrative hearings in Minneapolis,

Case 1:04-cv-00497-LMB

Document 57

Filed 09/26/2006

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and depositions for most of the week of September 18, 2006. Plaintiff's counsel also stated that defendant's leave in August made it difficult to communicate concerning the discovery. Accordingly, defendant requests that the Court enlarge the time for fact discovery until October 28, 2006. Respectfully Submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/Mark A. Melnick MARK A. MELNICK Assistant Director

September 26, 2006

s/Michael N. O'Connell MICHAEL N. O'CONNELL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 (202) 307-0282 (202) 514-8624 (fax) Attorneys for Defendant
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Case 1:04-cv-00497-LMB

Document 57

Filed 09/26/2006

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CERTIFICATE OF SERVICE I hereby certify that on September 26, 2006, a copy of the foregoing Defendant's Unopposed Motion to Enlarge Fact Discovery 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/Michael N. O'Connell

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