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

Case 1:03-cv-02771-MBH

Document 27

Filed 03/30/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS RONALD ADAMS CONTRACTOR, INC. ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 03-2771C (Judge Horn)

JOINT MOTION FOR ENLARGEMENT OF DISCOVERY As a result of the continued effects of Hurricane Katrina, the parties respectfully request that the Court enlarge the discovery deadline in this case by an additional six months, to September 31, 2006. The discovery deadline for this case is currently March 31, 2006. Because of the effects of Hurricane Katrina upon both plaintiff and defendant, both parties have been unable to proceed with discovery as scheduled. Specifically, plaintiff has been inundated with levy rebuilding work necessary to return the levees in the New Orleans area to their pre-Katrina condition prior to the upcoming hurricane season. Defendant's operations have been equally stressed by the rebuilding efforts from Hurricane Katrina. While counsel for both parties have attempted to schedule deposition dates, these dates have been consistently "trumped" by the press of this hurricane repair effort. While counsel for both parties continue their efforts to schedule depositions without causing disruption to the hurricane repair efforts, more time is needed to allow for this discovery. For these reasons, we respectfully request that the Court grant this joint motion and enlarge the discovery period of this case until September 30, 2006, with the parties to file the Joint Status Report, currently due on April 19, 2006, on October 10, 2006.

Case 1:03-cv-02771-MBH

Document 27

Filed 03/30/2006

Page 2 of 2

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director /s/ Phil B. Abernethy PHIL B. ABERNETHY Butler, Snow, O'Mara, Stevens & Cannada, PLLC AmSouth Plaza, 17th Floor 210 East Capitol Street Jackson, MS 39201 Telephone: (601) 985-4536 /s/ J. Reid Prouty J. REID PROUTY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn.: Classification Unit 8th Floor, 1100 L Street, N.W. Washington, DC 20530 Telephone: (202) 305-7586 Attorneys for Defendant

Attorney for Plaintiff March 30, 2006