Free Declaration - District Court of Federal Claims - federal

Case 1:90-cv-00162-LJB Document 687-9 Case 1:06-cv-00680-MMS Document 25

Filed 04/25/2008 Page 11of 22 Filed 05/12/2008 Page of

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

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KERRY R. HAMILTON, Plaintiff, v. UNITED STATES OF AMERICA, Defendant. )

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Case No. 06-680C (Judge Margaret M. Sweeney)

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JOINT STATUS REPORT Pursuant to the Court's Order issued on April 14, 2008, the parties have conferred and herewith file their joint status report as follows. 1. Counsel for defendant has advised counsel for plaintiff that the documents requested

by plaintiff in her First Request for Production of Documents will be produced on May 15, 2008. 2. Insofar as a briefing schedule is concerned, plaintiff proposes to file a dispositive

motion on July 1, 2008. Plaintiff presently plans to conduct one or more depositions of agents of defendant subsequent to the receipt of the documents to be produced by defendant on May 15, 2008, prior to the filing of her dispositive motion. 3. Defendant anticipates filing a dispositive motion on or before May 30, 2008. With

respect to any additional discovery that plaintiff did not request in accordance with the Court's March 7, 2008 order, and that the Court did not grant in its April 14, 2008 order, defendant believes that such additional discovery is inappropriate and anticipates opposing any request by plaintiff for such additional discovery. Defendant further proposes that the time period for responses and replies related to the Government's dispositive motion, and any cross motion, be determined in accordance with the Court's rules.
BERNSTEIN EXHIBIT 8

Case 1:90-cv-00162-LJB Document 687-9 Case 1:06-cv-00680-MMS Document 25

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Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JULES BERNSTEIN Bernstein & Lipsett, P.C. 1920 L Street, N.W. Suite 303 Washington, D.C. 20036 Deputy Director OF COUNSEL: LINDA LIPSETT Tel: (202) 296-1798 Fax: (202) 296-7220 S Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W. Washington, D.C. 20530 Washington, D.C. 20036 Tel: (202) 616-8275 Fax: (202) 305-7643 OF COUNSEL: Michael J. Dierberg William Rayel Trial Attorneys Commercial Litigation Branch Civil Division Department of Justice Attorneys for Defendant Dated: April 25, 2008

James & Hoffman, P.C. 1101 17th Street, N.W. Suite 510 Washington, D.C. 20036 Tel: (202) 496-0500 Fax: (202) 496-0555 Attorneys for Plaintiffs Dated: April 25, 2008