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

Case 1:98-cv-00720-GWM

Document 179

Filed 10/08/2003

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS PRECISION PINE & TIMBER, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 98-720C (Chief Judge Damich)

PLAINTIFF'S UNOPPOSED MOTION FOR A ONE DAY ENLARGEMENT OF TIME TO COMPLETE REVISED DISCOVERY REQUESTS For the reasons set forth below, Plaintiff hereby moves the Court to grant it one additional day to provide its revised responses to certain interrogatories. Plaintiff has conferred with defendant who has authorized plaintiff to inform the Court that defendant consents to the granting of the one additional day.

By Order dated October 2, 2003, the Court directed plaintiff to respond to certain interrogatories by Friday, October 10, 2003. Although plaintiff has been proceeding diligently in responding to these interrogatories, its progress has been slowed because Precision Pine's President has been unable to confer to the extent necessary with Precision Pine employees and/or counsel with regard to the draft responses due to travel. Additionally, one box of documents which contained, among other things, the TSSAs which are needed to respond to several of the interrogatories, was in defendant's possession for copying from Tuesday, September 30 to Tuesday, October 7 and was, therefore, unavailable to plaintiff.

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Case 1:98-cv-00720-GWM

Document 179

Filed 10/08/2003

Page 2 of 2

In light of these developments, the parties have conferred and plaintiff requests that the Court enter an order granting it one additional day, i.e. until on or before 10:00 a.m. on Tuesday, October 14, 2003 to serve its revised interrogatory responses to defendant by hand-delivery. Defendant consents to the entry of such an order.

This additional time will help plaintiff provide the fullest responses possible. Moreover, as a practical matter, the additional day should not affect defendant's review of the responses, because had plaintiff served the responses by mail or even by Federal Express on Friday, defendant, due to the intervening weekend and Columbus Day Holiday, would not have received the revised responses before Tuesday in any event.

Respectfully submitted:

s/ Alan I. Saltman SALTMAN & STEVENS, P.C. 1801 K Street, N.W. Suite M-110 Washington, D.C. 20006 (202) 452-2140 Counsel for Plaintiff OF COUNSEL: Richard W. Goeken SALTMAN & STEVENS, P.C. 1801 K Street, N.W. Suite M-110 Washington, D.C. 20006 (202) 452-2140 Dated: October 8, 2003 2