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

Case 1:03-cv-01720-RWG

Document 9

Filed 03/11/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS PROMATECH, INC., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 03-1720C (Senior Judge Gibson)

DEFENDANT'S UNOPPOSED MOTION TO MODIFY THE COURT'S DECEMBER 8, 2003 SCHEDULING ORDER Defendant, the United States, respectfully requests the Court to modify its December 8, 2003 scheduling order for the purpose of extending the discovery completion deadline by 25 days, from March 31, 2004 to April 25, 2004. Defendant has discussed this request with counsel for plaintiff, Promatech, Inc., who consents to and joins this request. The parties are currently exploring the possibility of settlement. However, the parties recognize the need to complete certain limited discovery if they are unable to resolve this action. The parties anticipate the need to complete limited document discovery and several depositions. Accordingly, defendant respectfully requests that the Court modify its December 8, 2003 scheduling order, extending the discovery completion deadline to April 25, 2004. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

Case 1:03-cv-01720-RWG

Document 9

Filed 03/11/2004

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s/Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director s/James M. Meister JAMES M. MEISTER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit, 8th Floor Washington, DC 20530 Tel: (202) 305-3079 Attorneys for Defendant OF COUNSEL: DANIEL P. GIMMY, ESQ. Law Department, New York United States Postal Service Date: March 11, 2004

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Case 1:03-cv-01720-RWG

Document 9

Filed 03/11/2004

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CERTIFICATE OF FILING I hereby certify that on this 11th day of March, 2004, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION TO MODIFY THE COURT'S DECEMBER 8, 2003 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/James M. Meister

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