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

Case 1:07-cv-00350-CCM

Document 38

Filed 09/10/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________ No. 07-350 T (Judge Christine O.C. Miller) J. CARDENAS & SONS FARMING, INC., JUAN CARDENAS AND GRACIELA CARDENAS Plaintiffs, v. THE UNITED STATES, Defendant,

No. 07-351 T RIO VISTA CORPORATION, JUAN CARDENAS AND GRACIELA CARDENAS, Plaintiffs, v. THE UNITED STATES, Defendant, __________ JOINT STATUS REPORT __________

Pursuant to the Court's order of August 11, 2008, the parties submit the following Joint Status Report.

-1-

Case 1:07-cv-00350-CCM

Document 38

Filed 09/10/2008

Page 2 of 3

1. As required by the Court's order of May 5, 2008, defendant prepared a detailed accounting for each period in issue in this consolidated action which was provided to plaintiffs' counsel. 2. Counsel for the parties have held two telephone conferences to discuss the accounting prepared by the Government in this action. In a telephone conference held on September 8, 2008, plaintiffs' counsel proposed a methodology for resolving all the accounting issues in this action. On September 9, 2008, plaintiffs' counsel forwarded to defendant's trial attorney computations in support of plaintiffs' settlement proposal. 3. Based upon the foregoing, the parties request that they be allowed until November 3, 2008, to complete all settlement negotiations in this action. In addition, the parties request that they be allowed to file a further Joint Status Report on or before October 15, 2008, advising the Court whether any of the accounting issues have been resolved and setting forth the parties' recommendations regarding further proceedings. 4. Plaintiffs' counsel has reviewed this Joint Status Report and has authorized counsel for the United States to sign this document electronically on behalf of plaintiffs and to file this report on behalf of both parties. // // // // // //

-2-

Case 1:07-cv-00350-CCM

Document 38

Filed 09/10/2008

Page 3 of 3

Respectfully submitted,

9/10/2008 Date

s/Martin A. Schainbaum MARTIN A. SCHAINBAUM A Professional Law Corporation 351 California Street, Suite 800 San Francisco, CA 94104-2406 (415) 777-1040 Attorney for Plaintiffs

9/10/2008 Date

s/Jennifer Dover Spriggs JENNIFER DOVER SPRIGGS Attorney of Record U.S. Department of Justice Tax Division Court of Federal Claims Section Post Office Box 26 Ben Franklin Post Office Washington, D.C. 20044 (202) 307-0840 NATHAN J. HOCHMAN Assistant Attorney General STEVEN I. FRAHM Acting Chief, Court of Federal Claims Section

9/10/2008 Date

s/Steven I. Frahm Of Counsel Attorneys for Defendant

-3-