Free Stipulation - District Court of Federal Claims - federal

Case 1:03-cv-00600-EJD

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

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

STIPULATION TO AMEND SCHEDULING ORDER
The parties, by and through undersigned counsel, respectfully request the Court to amend the Order dated October 24, 2005, for the reasons that the parties require additional time to complete all discovery, including expert discovery, and for the filing of any motions. Accordingly, the parties respectfully request the Court to extend the following deadlines:

Fact Discovery Schedule
1. 2. 3. 4. The defendant will answer the Complaint on or before January 20, 2006. The plaintiffs shall disclose the identity of fact witnesses by February 24, 2006. The defendant shall disclose the identity of fact witnesses by March 10, 2006. The parties shall propound all written discovery, including interrogatories, requests for

admissions, and document production requests by April 1, 2006. 5. The parties shall complete depositions of fact witnesses by May 16, 2006. Depositions are

tentatively scheduled to be held in Rapid City, South Dakota.

Expert Discovery Schedule
6. The plaintiffs shall disclose the identity of expert witnesses by April 1, 2006.

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7. 8. 9. 10. 11. 12.

The defendant shall disclose the identity of expert witnesses by April 21, 2006. The plaintiffs shall produce expert witness reports by August 1, 2006. The defendant shall produce expert witness reports by September 1, 2006. The parties shall complete the depositions of expert witnesses by October 1, 2006. The parties shall compete all discovery by November 1, 2006. The parties shall submit a Joint Status Report by November 15, 2006. The report should provide

the Court with a summary of the progress that has been made, the possibility of settlement, and a recommendation on how to proceed, including a proposed date for filing the Joint Preliminary Status Report ("JPSR"), the requirements for which are discussed in the Court's Standard Procedures Order of May 16, 2003. In completing the JPSR, the parties may except out those portions dealing with discovery, which are moot. 13. A post-discovery telephonic status conference shall be held on ____________________.

The parties shall contact Shirley Scott at (202) 357-6483 on the day before the status conference to provide the telephone number where they can be reached. Dated this 5th day of January, 2006.

THE UNITED STATES OF AMERICA

TRACEY ANN FISCHER

By: s/Susan V. Cook _____________________ Susan V. Cook General Litigation Section Environment & Natural Resources Division Department of Justice P.O. Box 663 Washington, D.C. 20044-0663 Attorneys for defendant

By:_s/Tracey Ann Fischer____________________ Tracey Ann Fischer 13366 Tilford Road Piedmont, South Dakota 57769 Attorneys for plaintiffs

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