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

Case 1:99-cv-00194-EGB

Document 100

Filed 04/02/2004

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) ____________________________________) MARKETING AND MANAGEMENT INFORMATION, INC.,

No. 99-194C (Judge Bruggink)

UNOPPOSED MOTION OF PLAINTIFF MMI TO EXTEND BY FOUR DAYS THE DEADLINE FOR MMI'S EXPERT REBUTTAL REPORT(S) Due to a serious and sudden illness in his family, Plaintiff's expert in this matter, Kenneth Metcalfe, was indisposed during the week of March 21 through 27, 2004 and unable to devote his attention to the expert reports submitted by the Government on March 19. Plaintiff therefore respectfully requests that the Court enter an order extending by four days -- from Monday, April 5, to Friday, April 9, 2004 -- the deadline for the service of a rebuttal report from Mr. Metcalfe. The Government does not oppose this motion, and the parties have agreed that the Government will, provided this motion is granted, have an additional week beyond the scheduled close of discovery on April 30 -- until Friday, May 7, 2004 -- to take discovery from Mr. Metcalfe specifically regarding his rebuttal report.*

The Government has indicated that additional time may be required to take discovery from persons other than Mr. Metcalfe if relevant to his rebuttal report. The parties will discuss that prospect as and if it becomes necessary.

*

Case 1:99-cv-00194-EGB

Document 100

Filed 04/02/2004

Page 2 of 2

Respectfully submitted,

__s/_____________________ CHARLES J. COOPER Cooper & Kirk, PLLC 1500 K Street, NW, Suite 200 Washington, DC 20005 (202) 220-9600 Counsel of Record for Plaintiff Of Counsel: Vincent J. Colatriano Derek Shaffer Cooper & Kirk, PLLC 1500 K Street, NW, Suite 200 Washington, D.C. 20005 (202) 220-9600

April 2, 2004

2