CALHOUN v. DOAN

MOTION for Extension of Time to respond to discovery

D.D.C.November 14, 2006

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA IONA D. CALHOUN, ) ) Plaintiff, ) ) v. ) Civil Action No. 06-1441 (HHK) ) LURITA A. DOAN, ADMINISTRATOR, ) GENERAL SERVICES ADMINISTRATION, ) ) Defendant. ) ) __________________________________________) MOTION TO EXTEND TIME TO RESPOND TO DISCOVERY Pursuant to Fed. R. Civ. P. 6(b)(1), defendant moves this Court for thirty days after this Court enters a Scheduling order setting discovery deadlines, to respond to plaintiff’s early discovery in this case. Defendant’s counsel has consulted with plaintiff’s counsel concerning this matter and the fact that plaintiff’s discovery requests are premature. However, defendant has been unable to consult specifically with counsel regarding this motion before its filing with the Court. This case is presently set for a Scheduling Conference on December 5, 2006, at which time discovery deadlines will be set. However, plaintiff has already served her first set of interrogatories and request for production of documents. These discovery requests were served on October 24, 2006. Defendant believes that plaintiff’s discovery is premature and has so advised plaintiff’s counsel. Undersigned counsel has requested that plaintiff withdraw the requests at this time but plaintiff has refused to do so. As undersigned counsel primarily assigned to this case will be out of the office from October 15, 2006, through the due date for responses to plaintiff’s discovery, it is respectfully requested that an extension of time be granted. Case 1:06-cv-01441-HHK-JMF Document 10 Filed 11/14/2006 Page 1 of 2 2 Accordingly, defendant requests to and including thirty days after the filing of this Court’s Scheduling Order be granted for responding to plaintiff’s discovery. A proposed order is attached. Respectfully submitted, /s/ JEFFREY A. TAYLOR, D.C. Bar # 498610 United States Attorney /s/ RUDOLPH.CONTRERAS, D.C. Bar # 434122 Assistant United States Attorney /s/ CLAIRE WHITAKER, D.C. Bar # 354530 Assistant United States Attorney United States Attorneys Office Civil Division 555 4th Street, N.W., Room E-4204 Washington, D.C. 20530 (202) 514-7137 Case 1:06-cv-01441-HHK-JMF Document 10 Filed 11/14/2006 Page 2 of 2