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

Case 1:07-cv-00338-NBF

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Filed 06/20/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS EDWARD F. CHANNELL, et al. ) ) ) ) ) ) ) ) ) )

Plaintiffs, v. THE UNITED STATES, Defendant.

Case No. 1:07-cv-00338-NBF (Judge Firestone)

JOINT STATUS REPORT Pursuant to the Court's June 6, 2008 Order, the parties respectfully submit the following as their Joint Status Report. The parties completed discovery on June 16, 2008. In addition to exchanging documents, the parties conducted depositions. Specifically, plaintiffs' counsel deposed defendant's designated Rule 30(b)(6) witness and defendant's counsel deposed five of the plaintiffs' witnesses. As a result of the information gathered during discovery, the parties believe that, over the next 90 days, efforts should be made toward settlement in this case. Accordingly, the parties respectfully request that the Court issue a stay in this matter until September 26, 2008, so the parties can seek to resolve this matter. On that date, the parties will submit a Joint Status Report and inform the Court whether efforts to settle this matter were successful. If the parties are unable to settle this matter by that date, or believe that the matter cannot be settled, they will ask the Court to issue a briefing schedule for summary judgment.

Case 1:07-cv-00338-NBF

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Respectfully submitted,

s/Molly A. Elkin MOLLY A. ELKIN Woodley & McGillivary 1125 15th Street, N.W, Suite 400 Washington, D.C. 20005 (202) 833-8855 Attorney of Record Bryan G. Polisuk Woodley & McGillivary 1125 15th Street, N.W. Suite 400 Washington, D.C. 20005 (202) 833-8855 Of Counsel Attorneys for Plaintiffs

GREGORY G. KATSAS Acting Assistant Attorney General

JEANNE E. DAVIDSON Director s/Todd M. Hughes TODD M. HUGHES Deputy Director

s/Ellen M. Lynch ELLEN M. LYNCH Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street N.W. Washington, D.C. 20530 TEL: (202) 353-7994 FAX: (202) 514-8624 Of Counsel: ELIZABETH PARIAH PATRICIA HARGRAVE Office of the General Counsel Broadcasting Board of Governors 330 Independence Avenue, S.W Room 3349 Washington, D.C. 20237 Attorneys for Defendant

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Case 1:07-cv-00338-NBF

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Filed 06/20/2008

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Certificate of Service I certify that the parties' Joint Status Report was filed and served electronically on the following party on June 20, 2008: Ellen M. Lynch Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, NW Washington, DC 20530

s/ Molly A. Elkin Counsel for Plaintiffs

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