Free Proposed Pretrial Order - District Court of Federal Claims - federal

Case 1:96-cv-00408-LAS

Document 113

Filed 02/26/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS INNOVAIR AVIATION, LTD. Plaintiff, v. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) )

No. 96-408C (Senior Judge Loren A. Smith)

JOINT PROPOSED SCHEDULING ORDER In accordance with the Court's status conference on February 9, 2007, the parties propose the following scheduling order: 1. The parties will engage in additional fact discovery from February 20, 2007, through June 29, 2007. 2. Expert discovery will commence on May 1, 2007. Plaintiff will identify its expert witness(es) on or before April 15, 2007. 3. On or before May 1, 2007, the plaintiff will submit to the defendant all expert reports in the manner and form required by Rule 26(a)(2), including all supporting documentation, spreadsheets, calculations, and formulas supporting damages calculations and spreadsheets, in hard copy and electronically;1 iterations of prior drafts need not be submitted. 4. 5. The defendant will identify its expert witness(es) on or before June 15, 2007. On or before July 2, 2007, the defendant will submit to the plaintiff all expert

The electronic production of expert work product shall be in the native file format, e.g., WordPerfect, Excel, PowerPoint, used to produce the work product, with links, formulas, and formatting intact as created by the expert. If the data is in a proprietary format or format that is not readable by Microsoft Office products, the data will be produced in a format that is readable by Microsoft Office product or such other format as agreeable between the parties.

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Case 1:96-cv-00408-LAS

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reports in the manner and form required by Rule 26(a)(2), including all supporting documentation, spreadsheets, calculations, and formulas supporting damages calculations and spreadsheets, in hard copy and electronically (as defined in footnote 1; iterations of prior drafts need not be submitted. 6. 7. The parties will conclude expert discovery on or before August 1, 2007. The meeting of counsel will occur on August 9, 2007, at which time the parties will exchange exhibit lists and witnesses lists as described in Appendix A, ¶ 13 of the Rules of the Court. 8. Plaintiff shall file its Memorandum of Contentions of Fact and Law, its witness list, and its exhibit list as described in Appendix A, ¶¶ 14, 15, and 16 on or before August 31, 2007. 9. The defendant shall file its Memorandum of Contentions of Fact and Law, its witness list, and its exhibit list as described in Appendix A, ¶¶ 14, 15, and 16 on or before September 28, 2007. 10. 11. A pre-trial conference shall be held October 9, 2007. A trial in this case shall commence on October 16, 2007.

Respectfully submitted,

PETER D. KEISLER Assistant Attorney General

/s/ Jeanne E. Davidson by Bryant G. Snee JEANNE E. DAVIDSON Acting Director

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/s/ Ty Cobb by H. Christopher Bartolomucci TY COBB Hogan & Hartson Columbia Square 555 Thirteenth Street, N.W. Washington, D.C. 20004-1109 Tele: (202) 637-5600 Facsimile: OF COUNSEL: H. CHRISTOPHER BARTOLOMUCCI AUDREY MOOG Hogan & Hartson Columbia Square 555 Thirteenth Street, N.W. Washington, D.C. 20004-1109 DATE: 2/22/07

/s/ Sheryl L. Floyd SHERYL L. FLOYD Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 616-8278 Facsimile: (202) 514-8624 DATE: 2/26/07

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CERTIFICATE OF FILING I hereby certify that on the 26th day of FEBRUARY, 2007, a copy of the "JOINT PROPOSED SCHEDULING ORDER" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

/s/ Sheryl L. Floyd