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

Case 1:97-cv-00733-BAF

Document 101

Filed 12/22/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS A. DEAN OSWALT, REINIE OSWALT, CRAIG OSWALT, MICHELLE OSWALT, KIRK OSWALT, and STACIE OSWALT, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 97-733C (Judge Futey)

DEFENDANT'S SECOND UNOPPOSED MOTION FOR ENLARGEMENT OF THE TIME FOR TAKING DISCOVERY Pursuant to Rule 6(b) of the Rules of the Court of Federal Claims, the United States respectfully requests that the Court enlarge the deadline for discovery in this case by 91 days, so that discovery will be due by Friday, March 30, 2007. The current deadline for discovery is December 29, 2006. The United States previously filed an unopposed motion for enlargement of the discovery schedule from September 29, 2006 to December 29, 2006, which the Court granted. The United States has determined that discovery is needed in this case and hopes to depose the plaintiffs in January or February 2007, depending on their availability. At present counsel are discussing the scheduling of these depositions, but have not established firm dates. An enlargement into March is requested to provide the United States time to conduct follow-up discovery, if needed. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

Case 1:97-cv-00733-BAF

Document 101

Filed 12/22/2006

Page 2 of 3

S/Bryant G. Snee BRYANT G. SNEE Assistant Director S/Brian T. Edmunds BRIAN T. EDMUNDS Trial Attorney U.S. Department of Justice Civil Division Commercial Litigation Branch 1100 L Street, NW Attn: Classification Unit 8th Floor Washington, D.C. 20530 [email protected] Tel: (202) 616-8253 Fax: (202) 307-0972 December 22, 2006 Attorneys for Defendant

Case 1:97-cv-00733-BAF

Document 101

Filed 12/22/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on December 22, 2006, a copy of the foregoing "DEFENDANT'S SECOND UNOPPOSED MOTION FOR ENLARGEMENT OF THE TIME FOR TAKING DISCOVERY" was filed electronically. Parties may access this filing through the Court's system.

s/Brian T. Edmunds