Free Motion for Status Conference - District Court of Federal Claims - federal

Case 1:94-cv-00522-MCW

Document 295

Filed 11/07/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS FIRST ANNAPOLIS BANCORP, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 94-522C (Judge Williams)

DEFENDANT'S CONSENT MOTION FOR STATUS CONFERENCE Pursuant to Rules 1 and 7 of the Rules of the Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests that the Court schedule a status conference at its earliest convenience to discuss the pre-trial schedule for the damages trial that is currently scheduled to begin on January 8, 2007. Assuming that the pre-trial conference were to occur on January 5, 2007, the last business day prior to the start of trial, pursuant to Appendix A of the RCFC, the initial meeting of counsel should have taken place no later than November 2, 2006, where the parties were to have, among other things, exchanged witness and exhibit lists; however, due to the conditional nature of the January 8, 2007 trial date, we have yet to meet with counsel for First Annapolis Bancorp, Inc. ("Bancorp"). Under this schedule, Bancorp's contentions of fact and law would be due next week, November 16, 2006. Accordingly, we believe that it would be beneficial to discuss the pre-trial schedule with the Court. We have discussed this matter with plaintiff's counsel and Bancorp consents to our request for a status conference.

Case 1:94-cv-00522-MCW

Document 295

Filed 11/07/2006

Page 2 of 3

Respectfully submitted, STUART E. SCHIFFER Deputy Assistant Attorney General JEANNE E. DAVIDSON Deputy Director s/William F. Ryan WILLIAM F. RYAN Assistant Director s/Richard B. Evans OF COUNSEL: TIMOTHY ABRAHAM MELINDA HART MARK PITTMAN DELISA M. SANCHEZ Trial Attorneys RICHARD B. EVANS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Telephone: (202) 353-7760 Facsimile: (202) 305-7643 Attorneys for Defendant

November 7, 2006

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Case 1:94-cv-00522-MCW

Document 295

Filed 11/07/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on November 7, 2006, a copy of the foregoing "DEFENDANT'S CONSENT MOTION FOR STATUS CONFERENCE" 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 B. Evans

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