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

Case 1:04-cv-00461-BAF

Document 39

Filed 05/17/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

CADDELL CONSTRUCTION CO., INC., ) ) Plaintiff, ) ) v. ) ) ) UNITED STATES OF AMERICA, ) ) Defendant. )

No. 04-461C (Judge Bohdan A. Futey)

PLAINTIFF'S PROPOSED REVISED PRE-TRIAL SCHEDULE In accordance with the Court's Order dated May 9, 2006, Plaintiff submits this Proposed Revised Pre-Trial Schedule and estimated time for trial for the reason that Plaintiff and Defendant were unable to agree: 1. Defendant's expert reports: Defendant's expert reports shall be submitted to Plaintiff

by July 1, 2006. 2. Plaintiff's Expert Discovery: If Plaintiff is to undertake any such discovery of

Defendant's expert witnesses, such discovery shall be concluded by August 15, 2006. 3. Plaintiff's Rebuttal Expert Reports: Such Rebuttal Reports shall be filed by

October 1, 2006. 4. Exhibit and Witness Lists: The parties shall exchange witness and exhibit lists in

accordance with Appendix A, ¶¶ 13(a) and (b) on October 15, 2006. The parties shall confer in accordance with requirements of Appendix A, ¶¶ 13(c)(1)-(6) on October 15, 2006. 5. Memorandum of Contentions of Fact and Law: Plaintiff shall file its Memorandum

of Contentions of Fact and Law per Appendix A, ¶ 14(a) and its witness and exhibit lists on November 1, 2006. Defendant shall file its Memorandum of Contentions of Fact and Law and its witness and exhibit lists on November 27, 2006.

Case 1:04-cv-00461-BAF

Document 39

Filed 05/17/2006

Page 2 of 2

6.

Stipulations: The Stipulations agreed upon by the parties shall be included in the Pre-

Trial Order which shall be submitted to the Court at the Pre-Trial Conference to be held on December 18, 2006 at 2:30 pm. 7. Estimated Trial Time: Plaintiff estimates that trial of this cause will require 4-5 days. Respectfully Submitted, CADDELL PLAINTIFF CONSTRUCTION CO., INC.,

By:

/s/ David W. Mockbee David W. Mockbee Mary Elizabeth Hall MOCKBEE HALL & DRAKE, P.A. Lamar Life Building, Suite 1000 317 E. Capitol Street Jackson, MS 39201 (601) 353-0035 - Telephone (601) 353-0045 - Facsimile ITS ATTORNEYS

CERTIFICATE OF SERVICE I, David W. Mockbee, do hereby certify that I have this day caused to be filed via the Official Electronic Document Filing System of the United States Court of Federal Claims ("CM/ECF") a true and correct copy of the above and foregoing Plaintiff's Proposed Revised PreTrial Schedule. Copies of this document will be transmitted via the Court's CM/ECF System to all counsel of record. Additional copies may be obtained through the Court's CM/ECF System. Dated: May 17, 2006

/s/ David W. Mockbee David W. Mockbee