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

Case 1:06-cv-00377-GWM

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Filed 12/04/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ROME RESEARCH CORPORATION, Plaintiff, v. THE UNITED STATES Defendant. ) ) ) ) ) ) No. 06-377C ) (Judge George W. Miller) ) ) )

JOINT STATUS REPORT Defendant, the United States, respectfully submits the following status report upon behalf of the parties. On September 25, 2006, the Court continued the stay in this case until November 27, 2006 to permit the parties an opportunity to settle this action. The Court directed the parties to file a We respectfully advise

joint status report on December 4, 2006.1

the Court of the status of settlement discussions in this case and how the parties believe the case should proceed. Counsel for the parties have agreed in principal to a proposed settlement that can be recommended to the authorized representative of the Attorney General and would resolve a substantial part of this case. Specifically, the proposed

settlement would resolve counts one and five of the complaint, and the portion of count seven that relates to counts one and
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The order states that, "[i]f settlement discussions break down, the parties shall file a joint status report indicating how they believe the case should proceed not later than Monday, December 4, 2006." However, the parties believe that the Court intended for the parties to file a status report regardless of the status of settlement discussions.

Case 1:06-cv-00377-GWM

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five.

The parties will attempt to finalize the proposed partial

settlement in an expedited fashion. In addition, the parties are still in negotiations regarding plaintiff's other claims and they remain hopeful that they can settle those claims. However, so as not to cause undue delay,

the parties respectfully suggest that the Court set a deadline of January 12, 2006 to respond to whatever portion of the complaint remains in the case as of that date. Plaintiffs' counsel has reviewed this status report and agrees with its contents. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Bryant G. Snee BRYANT G. SNEE Assistant Director s/Richard P. Schroeder RICHARD P. SCHROEDER Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit Eighth Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7788 Fax: (202) 353-7988 Attorneys for Defendant December 4, 2006

Case 1:06-cv-00377-GWM

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 4 day of December, 2006, the "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.
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s/Richard P. Schroeder