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

Case 1:03-cv-00289-FMA

Document 173

Filed 10/26/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS UNITED MEDICAL SUPPLY COMPANY, INC., Plaintiff v. THE UNITED STATES, Defendant

CASE NO: 03-CV-289 Judge Allegra

PLAINTIFF'S MOTION FOR ENLARGEMENT OF FACT DISCOVERY DEADLINE TO THE HONORABLE UNITED STATES COURT OF FEDERAL CLAIMS: Plaintiff United Medical Supply Company, Inc. files this Motion for Extension of Fact Discovery Deadline for the following reasons: On March 24, 2007 the Government advised Plaintiff that it would need substantial additional time to complete Plaintiff's pending discovery requests and that it intended to seek approximately enlargement by another month for each of the pending deadlines. On March 26, 2007 the Government advised Plaintiff that would be unable to file its motion before Monday October 29, 2007. Accordingly to have a timely motion with respect to the October 26, 2007 deadline on file and to preserve Plaintiff's rights to respond, if necessary, to the anticipated motion to be filed by the Government, Plaintiff requests that the October 26, 2007 deadline for close of fact discovery be extended until October 29, 2007 so that the Government can timely file its next motion for enlargement of existing deadlines. Signed October 26, 2007.

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Case 1:03-cv-00289-FMA

Document 173

Filed 10/26/2007

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Respectfully submitted,

s/Frank L. Broyles Frank L. Broyles TX State Bar No. 03230500 Goins, Underkofler, Crawford & Langdon, LLP 1201 Elm Street 4800 Renaissance Tower Dallas, Texas 75270 (214) 969-5454 (214) 969-5902 Fax Attorney for Plaintiff

CERTIFICATE OF SERVICE On March 5, 2003 the foregoing motion for extension was served on the persons shown below by the method shown below. s/Frank Broyles

PERSONS SERVED: Kyle Chadwick via email and the Clerk's Electronic Service System.

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