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

Case 1:01-cv-00718-ECH

Document 23

Filed 07/26/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) RON AND BETTY BLENDU, et al., ) ) Plaintiffs, ) No. 01-718 L v. ) ) Judge Emily C. Hewitt UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________) JOINT MOTION TO EXTEND TITLE AND LIABILITY RELATED DISCOVERY Pursuant to the Court's Order of May 11, 2006, discovery with respect to title and liability-related issues was re-opened. Under the same Order, this discovery period is set to close on August 4, 2006. The parties hereby jointly request a 6-week extension of this discovery period, to and including September 15, 2006. In support of this joint motion, the parties state that they are making good progress toward the completion of title and liability-relation discovery. On June 12, 2006, Plaintiffs served Defendant with its first set of responses to Defendant's First Set of Interrogatories and Requests for Production. These responses provided requested information for most of the named plaintiffs. Plaintiffs are continuing to gather the requested information for the remaining named plaintiffs, and expect to be able to complete this work and serve Defendant with the requested information within the next month. The parties also intend to work cooperatively to address any follow-up discovery required by either side. Once this discovery is completed, the parties will be prepared to propose a schedule for further proceedings in this matter. Accordingly, the parties jointly request a 6-week extension of time to complete their title and liability-related discovery, to and including September 15, 2006. 1

Case 1:01-cv-00718-ECH

Document 23

Filed 07/26/2006

Page 2 of 2

Dated: July 26, 2006

Respectfully submitted, SUE ELLEN WOOLDRIDGE Assistant Attorney General Environment & Natural Resources Division s/ Lary C. Walker LARY C. WALKER WALKER LAW OFFICE 232 East Main Post Office Box 828 Weiser, ID 83672 TEL: (208) 414-0390 FAX: (208) 414-0404 E-MAIL: [email protected] Attorney for Plaintiffs Attorney for Defendant s/ Kristine S. Tardiff KRISTINE S. TARDIFF United States Department of Justice Environment & Natural Resources Division Natural Resources Section 53 Pleasant Street, 4th Floor Concord, NH 03301 TEL: (603) 230-2583 FAX: (603) 225-1577 E-MAIL: [email protected]

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