Free Status Report - District Court of Federal Claims - federal

Case 1:94-cv-00518-EGB

Document 153

Filed 04/30/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS MONARCH ASSURANCE, P.L.C., and THOMAS PATRICK DENTON TAYLOR, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) )

No. 94-518C (Judge Bruggink)

DEFENDANT'S STATUS REPORT Defendant respectfully submits the following status report, upon behalf of both parties, pursuant to the Court's order. Plaintiff's counsel has reviewed this status report and has authorized defendant to file it upon behalf of both parties. On April 29, 2004, plaintiff's counsel informed Government counsel that plaintiff would not agree to any of the measures that the Government has proposed to safeguard classified information that may be revealed during the depositions that plaintiff intends to conduct in the United Kingdom. the parties propose the following schedule. The Government will file, by June 1, 2004, a brief that identifies the safeguards that the United States believes should be included in the letters rogatory that the Court will send to the appropriate court in the United Kingdom, pursuant to plaintiff's request to conduct depositions in the United Kingdom. The Government's brief will also explain why it is necessary to Accordingly,

Case 1:94-cv-00518-EGB

Document 153

Filed 04/30/2004

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request the British court to implement the safeguards proposed by the Government. Plaintiff will then have until July 2, 2004 to Finally, the

file a response to the Government's brief.

Government will have until July 19, 2004, to file its reply brief. Respectfully submitted, PETER D. KEISLER Assistant Attorney General /s David M. Cohen DAVID M. COHEN Director /s Thomas D. Dinackus THOMAS D. DINACKUS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, DC 20530 Tele: (202) 307-6289 Fax: (202) 514-7969 Attorneys for Defendant OF COUNSEL: JOHN RADSAN Office of General Counsel Central Intelligence Agency April 30, 2004

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Case 1:94-cv-00518-EGB

Document 153

Filed 04/30/2004

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NOTICE OF FILING I hereby certify that on April 30, 2004, a copy of the foregoing "DEFENDANT'S 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. I hereby further certify that on April 30, 2004, I caused to be served by United States mail (first class, postage prepaid) copies of the foregoing "DEFENDANT'S STATUS REPORT" addressed as follows: Raphael S. Moore, Esq. 413 F Street Davis, CA 95616

/s Thomas D. Dinackus