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

Case 1:06-cv-00383-FMA

Document 57

Filed 05/13/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ______________________________ No. 06-383 T (Honorable Francis M. Allegra)

HARRY G. SCHORTMANN, Jr. and JACQUELINE SCHORTMANN, Plaintiffs, v. THE UNITED STATES, Defendant. __________________ JOINT STATUS REPORT __________________ The parties submit this joint status report, pursuant to the Court's April 9, 2008 order, to discuss how this case should proceed and the need for additional discovery. As directed by the Court, counsel for the parties have discussed settlement of this case. Given the Court's conclusion in its April 9, 2008 order denying the defendant's motion for summary judgment based on the existence of genuine issues of fact, counsel for the parties believe that additional discovery is necessary to have meaningful settlement discussions and to prepare for trial in this case.

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Case 1:06-cv-00383-FMA

Document 57

Filed 05/13/2008

Page 2 of 2

Accordingly, the parties request an additional 140 days from the date of this filing, to and including September 30, 2008, to conduct further discovery in this case, including any written discovery or discovery by deposition testimony. Plaintiffs' counsel joins in this status report and has authorized defendant to sign on her behalf. Respectfully submitted, s/Mary E. Rinaldi Mary E. Rinaldi, Esq. Morgan, Lewis & Bockius LLP 1111 Pennsylvania Ave., N.W. Washington, D.C. 20004 Attorney for Plaintiffs May 13, 2008 s/Jacob Christensen JACOB E. CHRISTENSEN 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 Voice: (202) 307-0878 Fax: (202) 514-9440 Email: [email protected] NATHAN J. HOCHMAN Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section W. C. RAPP Senior Trial Attorney s/W.C. Rapp Of Counsel May 13, 2008

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