Free Joint Status Report - District Court of Federal Claims - federal

Case 1:01-cv-00479-FMA

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Filed 08/10/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) ____________________________________) UNITEDHEALTHCARE OF ILLINOIS, INC.,

No. 01-479C (Judge Allegra)

JOINT STATUS REPORT Pursuant to this Court's February 11, 2004 Order directing the parties to submit a joint status report every 60 days regarding the progress of settlement, the parties submit the following status report: The parties tentatively agreed to settlement terms that could be recommended to the appropriate settlement authority within the Department of Justice on or about February 6, 2004. Counsel for the Government has prepared the required internal memorandum regarding the proposed settlement. Review of the settlement at the National Courts Section level has been completed. The memorandum was sent for higher level review and approval several weeks ago. In light of the above, the parties respectfully request that the Court continue to stay all proceedings in this case to provide the parties with the opportunity to complete the settlement process.1

1 Plaintiff further states that it has been awaiting approval of this settlement for over six months now. Absent immediate progress, counsel for Plaintiff believes that a status conference with the Court would assist in the ultimate resolution of this dispute.

Case 1:01-cv-00479-FMA

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Filed 08/10/2004

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

FRANKLIN E. WHITE, JR. Assistant Director

___________/s/_______________ CHRISTOPHER FLYNN King, Pagano & Harrison 1730 Pennsylvania Avenue, N.W. Suite 900 Washington, DC 20006 (202) 371-6800 Facsimile: (202) 371-6770

RICHARD P. SCHROEDER Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Commercial Litigation Branch 1100 L Street, N.W. Washington, DC 20530 (202) 305-7562 Facsimile: (202) 353-7988 Attorneys for Defendant

Counsel for Plaintiff UnitedHealthcare of Illinois, Inc. Dated: August 10, 2004 Dated: August 10, 2004

2

Case 1:01-cv-00479-FMA

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Filed 08/10/2004

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CERTIFICATE OF FILING I hereby certify that on August 10, 2004, a copy of foregoing JOINT STATUS REPORT 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/ Andrew B. Dahlinghaus