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

Case 1:04-cv-00461-BAF

Document 15

Filed 07/28/2004

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS CADDELL CONSTRUCTION CO., INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) No. 04-461C ) (Judge Diane Gilbert Sypolt) ) ) )

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 30 days, to and including August 27, 2004, within which to submit its initial disclosures to the plaintiff. Pursuant to the

Court's order of June 30, 2004, defendant's initial disclosures are currently due on July 28, 2004. Plaintiff's counsel has

indicated that plaintiff does not oppose this motion. The parties have already conducted the early meeting of counsel and have agreed upon a plan for document discovery that will lead to other forms of fact and expert discovery. parties will present this plan to the Court in the joint preliminary status report, due on September 9, 2004. are working amicably together in this regard. The parties The

Having only

recently filed the answer, however, defendant is not prepared to formally submit its initial disclosures within the current time frame ­ although the informal discussion and exchange of that type of information has already begun. Defendant's counsel

requires the requested enlargement to ensure that its initial disclosures are accurate and complete when submitted.

Case 1:04-cv-00461-BAF

Document 15

Filed 07/28/2004

Page 2 of 2

For the foregoing reasons, we respectfully request the Court to grant our motion for an enlargement of time of 30 days. Respectfully submitted, PETER D. KEISLER Assistant Attorney General
DAVID M. COHEN Director s/Bryant G. Snee BRYANT G. SNEE Assistant Director s/Brian S. Smith BRIAN S. SMITH Attorney Commercial Litigation Branch Civil Division Department of Justice Washington, D. C. 20530 Tele: (202) 616-0391 Fax: (202) 353-7988 Attorneys for Defendant July 28, 2004

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