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

Case 1:07-cv-00267-FMA

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Filed 03/28/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SIMON ROOFING AND SHEET METAL CORP., Plaintiff, ) ) ) ) ) ) ) ) ) )

No. 07-267-C No. 07-409-C Judge Allegra

THE UNITED STATES, Defendant.

JOINT STATUS REPORT Simon Roofing and Sheet Metal Corp. ("Simon Roofing" or "Plaintiff") and the United States ("Defendant") respectfully submit this joint status report in the above-captioned action, as required by the Court's orders dated December 3, 2007 and February 7, 2008. Pursuant to the Court's orders, the parties are required to file a joint status report every 28 days to indicate to the Court the progress of settlement negotiations. The parties last filed a joint status report on February 29, 2008. Since February 29, 2008, the parties have continued to exchange correspondence regarding the written settlement proposal submitted on behalf of Simon Roofing to Defendant. The parties continue to believe that they will be able to resolve these consolidated cases without the need for further litigation or judicial involvement. Defendant continues to consider Plaintiff's offer to settle the consolidated cases. On or about March 7, 2008, Plaintiff's provided a revised settlement agreement to Defendant. Plaintiff's offer of compromise remains under consideration by Defendant and is currently undergoing an approval review. The parties continue to believe that settlement will be reached. Accordingly, the parties respectfully request that they be permitted until April 25, 2008

Case 1:07-cv-00267-FMA

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to finalize settlement discussions. Should a Joint Stipulation of Settlement not be filed by that time, the parties will provide the Court with an updated status report on April 25, 2008.

Respectfully submitted, /s/ Anna K. Raske ANNA K. RASKE (OH#0066997) JEFFREY D. ZIMON (OH#0059565) TASIA E. MCINTYRE (OH# 0081259) BENESCH, FRIEDLANDER, COPLAN & ARONOFF LLP 2300 BP Tower, 200 Public Square Cleveland, Ohio 44114-2378 Phone: (216) 363-4500 Fax: (216) 363-4588 E-mail: [email protected] [email protected] [email protected] Counsel for Plaintiff JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director /s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director /s/ David M. Hibey DAVID M. HIBEY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 307-0163 Fax: (202) 514-8624 Counsel for Defendant Date: March 28, 2008

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Case 1:07-cv-00267-FMA

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this, 28th day of March, 2008, a copy of the foregoing "Joint 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.

s/ Anna K. Raske

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