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

Case 1:07-cv-00126-LMB

Document 23

Filed 02/29/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SI-NOR INCORPORATED, a California Corporation, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-126C (Judge Lawrence M. Baskir)

JOINT STATUS REPORT Pursuant to this Court's order of January 2, 2008, the parties respectfully submit this joint status report. Fact discovery in this matter is currently scheduled to close on February 29, 2008. Defendant has filed a motion to dismiss, or, in the alternative, to stay proceedings in this case based upon the suspension of Si-Nor's corporate powers by California's Secretary of State. Plaintiff intends to oppose this motion, and is making efforts to have its corporate powers reinstated. Plaintiff's opposition is not yet due. The parties are in agreement that, should the Court deny defendant's motion and decline to dismiss this matter or stay proceedings, both are in need of additional time to complete

Case 1:07-cv-00126-LMB

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discovery, due to the disruption of their intended schedule by the suspension at issue. Respectfully submitted, JEFFREY S. BUCKHOLTZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director

s. Deborah A. Bynum DEBORAH A. BYNUM Assistant Director

s/ Joseph D. Curd JOSEPH D. CURD Curd, Galindo & Smith 301 E. Ocean Boulevard Suite 1700 Long Beach, CA 90802 Tel: (562) 624-1177 Fax: (562) 624-1178

s/ A. Bondurant Eley A. BONDURANT ELEY Trial Attorney Commercial Litigation Branch Department of Justice 1100 L St., N.W. Classification Unit, 8th Floor Washington, D.C. 20530 Tel: (202) 616-8254 Fax: (202) 514-8624 Counsel for Defendant

Counsel for Plaintiff February 29, 2008

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Case 1:07-cv-00126-LMB

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CERTIFICATE OF FILING I hereby certify that on this 29th day of February 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/ A. Bondurant Eley

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