Free Motion for Discovery - District Court of Federal Claims - federal

Case 1:98-cv-00405-ECH

Document 207

Filed 07/25/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

CROMAN CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant.

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No. 98-405C (Judge Hewitt)

PLAINTIFF'S UNOPPOSED MOTION TO SET CUT-OFF DATE FOR FACT DISCOVERY On July 15, 2008, the parties filed joint status reports in the instant case and in the related proceeding, Croman Corp., v. United States, No. 01-40C, which is also pending before the Court. In the Joint Status Reports, the parties requested that the stay of proceeding be lifted, that all fact discovery be completed by January 15, 2009 and that the parties report back to the Court regarding the need for further proceedings in the cases by January 30, 2009. The Court's order of July 22, 2008, did set a date for the parties to report back to the Court, but did not specifically include the discovery cut-off date of January 15, 2009.

Plaintiff believes that the expeditious litigation of the damages phase of this case is in order. Toward that end, plaintiff respectfully requests that the Court enter an order specifically setting January 15, 2009 as the cut-off date for all fact discovery.1 Counsel for plaintiff has discussed this matter with counsel for the government who advises that the government does not oppose setting a cut-off date for fact discovery of January 15, 2009.

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A motion seeking a discovery cut-off date has been filed in Case No. 01-40C as well. 1

Case 1:98-cv-00405-ECH

Document 207

Filed 07/25/2008

Page 2 of 2

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: July 25, 2008

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