The parties alerted Judge Lamberth this afternoon fact discovery won’t be completed today and they need more time to depose witnesses and review documents. Further, the parties believe the U.S. Supreme Court’s decision in Collins might trigger additional discovery. With that in mind, the parties ask Judge Lamberth to continue all of the deadlines established earlier this year, and tell the Court they’ll propose new deadlines within three weeks following publication of the Collins decision. A copy of the filing tendered to Judge Lamberth today is attached to this e-mail message.
