Free Motion to Compel - District Court of Federal Claims - federal

Case 1:99-cv-00961-LAS

Document 106

Filed 03/21/2008

Page 1 of 1

IN THE UNITED STATES COURT OF FEDERAL CLAIMS WHITE BUFFALO CONSTRUCTION, INC., an Oregon corporation, PLAINTIFF'S MOTION TO COMPEL Plaintiff, v. THE UNITED STATES, Defendant. No. 99-961C (Consolidated with Case Nos. 07-738C and 00-415C) Senior Judge Loren A. Smith Electronically Filed March 21, 2008

RCFC 37(a)(2)(A) CERTIFICATION The undersigned counsel certifies pursuant to RCFC 37(a)(2)(A) that movant has in good faith conferred with counsel for defendant in an effort to secure disclosure without court action. MOTION Pursuant to RCFC 37, plaintiff White Buffalo Construction, Inc. ("White Buffalo") moves to the government to produce all discoverable documents requested related to White Buffalo's bad-faith claim and on the statute of limitations issue pursuant to White Buffalo's Requests for Production as set forth in the accompanying papers. This motion is based on the accompanying memorandum, the Declaration of Scott J. Kaplan and the pleadings and papers on file herein. DATED: March 21, 2008. STOEL RIVES LLP

/s/ Scott J. Kaplan Richard E. Alexander, OSB No. 69002 Scott J. Kaplan, OSB No. 913550 Attorneys of Record for White Buffalo Construction, Inc. Stoel Rives LLP 900 SW Fifth Avenue, Suite 2600 Portland, OR 97204-1268 Telephone: (503) 224-3380 Facsimile: (503) 294-9167

Portlnd3-1622495.1 0079700-00014

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