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

Case 1:01-cv-00479-FMA

Document 26

Filed 04/12/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) ) ) ) ) )

UNITEDHEALTHCARE OF ILLINOIS, INC. Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant.

No. 01-479C (Judge Allegra)

JOINT STATUS REPORT Pursuant to this Court's order directing the parties to submit a joint status report on or before April 12, 2004, the parties respectfully submit the following joint status report: The parties have tentatively agreed to settlement terms that can be recommended to the appropriate settlement authority within the Department of Justice. Counsel for the Government has prepared the required internal memorandum regarding the proposed settlement. The memorandum has been reviewed by Government counsel's supervisor and returned for additional changes. At the Government's request, plaintiff's counsel has submitted a revised letter to clarify certain non-monetary aspects of the settlement proposal. This letter was requested to enable the agency to make a formal recommendation regarding the proposed settlement. Government counsel intends to resubmit the internal settlement paperwork in an expeditious manner. In light of the above, the parties respectfully request that the Court stay all proceedings in this case to provide the parties with the opportunity to complete the settlement process.

Case 1:01-cv-00479-FMA

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Filed 04/12/2004

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director s/ Christopher Flynn CHRISTOPHER FLYNN King, Pagano & Harrison 1730 Pennsylvania Avenue, N.W. Suite 900 Washington, DC 20006 (202) 371-6800 Facsimile: (202) 371-6770 s/ Richard P. Schroeder 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 Dated: April 12, 2004

Counsel for Plaintiff UnitedHealthcare of Illinois, Inc. Dated: April 12, 2004

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Case 1:01-cv-00479-FMA

Document 26

Filed 04/12/2004

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Certificate of Filing

I hereby certify that on April 12, 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/ Richard P. Schroeder