JOINT MOTION TO MODIFY DISCOVERY SCHEDULE
In accordance with Rule 6(b) of the Rules of the United States Court of Federal Claims and this Court’s order dated September 8, 2014, the parties respectfully request a three-month exten- sion of time to complete discovery in this case. Jurisdictional discovery is currently scheduled to be completed by March 27, 2015. The requested extension of time, if granted, would extend this period to June 29, 2015.
There is good cause for the parties’ request. On September 5, 2014, the parties informed the Court that “it is likely that discovery can be completed by March 27, 2015.” Joint Status Re- port at 1, Sept. 5, 2014 (ECF No. 90). This proposed discovery completion date was based, in part, on defendant’s estimate that it would complete the production of non-privileged, responsive documents by mid-January 2015. Id. On September 8, 2014, the Court issued an order directing that jurisdictional discovery be completed by March 27, 2015, and that, if the parties needed addi- tional time to complete discovery, they should file an appropriate motion. Order at 1, Sept. 8, 2014 (ECF No. 92).
Given a number of circumstances, at least some of which were explained at recent status conferences, defendant now estimates that its document production will be completed by April
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) (Judge Sweeney)
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Case 1:13-cv-00465-MMS Document 136 Filed 03/06/15 Page 2 of 2
2015. In light of this new estimate, the parties have discussed the discovery schedule, and have agreed that the discovery deadline should be extended until late June.
The parties have agreed that, if the extension of time is granted, defendant will produce to Fairholme every two weeks (or more frequently): (1) any responsive non-privileged documents the Government has reviewed and has not previously produced; and (2) a revised privilege log containing responsive documents that the Government has identified as privileged.
For these reasons, the parties respectfully request that the Court grant an extension of time
of three months, from March 27 to June 29, 2015, for the parties to complete the discovery permit-
ted by the Court in this case.
Date: March 6, 2015
