Free Motion to Amend Schedule - District Court of Federal Claims - federal

Case 1:03-cv-00600-EJD

Document 45

Filed 11/28/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) ) ) ) Plaintiffs, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) ) CHEYENNE RIVER SIOUX TRIBE, et al.,

Civil No. 03-600 L Chief Judge Edward J. Damich

JOINT MOTION TO AMEND DISCOVERY SCHEDULE ___________________________________________________

The parties, by and through undersigned counsel, respectfully request that the Court amend its current scheduling order dated April 6, 2006, for the reasons that the parties require additional time to complete expert discovery. Specifically, plaintiffs' experts required additional time to complete their reports which had the effect of pushing back the balance of the expert discovery schedule. The parties are pleased to report that they have completed the depositions of fact witnesses, and that written discovery has been propounded and responded to. Accordingly, the parties respectfully propose the following extended schedule to the Court: Plaintiffs shall produce their expert reports by January 15, 2007; Depositions of Plaintiffs' experts shall occur by February 16, 2007; Defendant shall produce their expert reports by February 9, 2007;

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Case 1:03-cv-00600-EJD

Document 45

Filed 11/28/2006

Page 2 of 2

Depositions of Defendant's experts shall occur by March 9, 2007; The parties shall complete all discovery by March 31, 2007; The parties shall submit a Joint Status Report on or before April 15, 2007. Dated: November 28, 2006. Respectfully submitted,

s/ Cris Palmer by s/ Susan V. Cook J. CRISMAN PALMER 440 Mt. Rushmore Rd. P. O. Box 8045 Rapid City, SD 57709 Tele (605) 342-1078 Fax (605) 342-9503 [email protected] Counsel for Plaintiffs

SUE ELLEN WOOLDRIDGE Assistant Attorney General Environmental & Natural Resources Division

s/ Susan V. Cook SUSAN V. COOK, Senior Attorney JAMES D. GETTE, Trial Attorney Natural Resources Section Environment & Natural Resources Division United States Department of Justice P.O. Box 663 Washington, D.C. 20044 Tele (202) 305-0470 Fax (202) 305-0506 [email protected] Counsel for Defendant 360228.1