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

Case 1:01-cv-00479-FMA

Document 25

Filed 02/10/2004

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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 February 10, 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 plaintiff has submitted a written settlement proposal and a draft settlement agreement to the Government. Counsel for the Government will finalize the required internal memorandum regarding the proposed settlement and submit it for review shortly. 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

Document 25

Filed 02/10/2004

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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: February 9, 2004

Counsel for Plaintiff UnitedHealthcare of Illinois, Inc. Dated: February 9, 2004

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Case 1:01-cv-00479-FMA

Document 25

Filed 02/10/2004

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Certificate of Filing

I hereby certify that on February 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/Richard P. Schroeder