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

Case 1:06-cv-00354-MBH

Document 14

Filed 02/28/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS AMERICAN CASUALTY CO. OF READING, PENNSYLVANIA, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) No. 06-354C ) (Judge Horn) ) ) )

JOINT STATUS REPORT In accordance with the Court's order entered February 21, 2007, the parties report that they have resolved the matters raised in plaintiff American Casualty's motion to compel regarding the Government's response to a request for production of documents. The parties have agreed that the Government shall provide a response to the request for production of documents on or before March 30, 2007. This case involves Government documents that are stored in four geographically diverse offices which has contributed to the difficulty the Government has met in responding to American Casualty's document request. Counsel for the Government has made repeated efforts to obtain documents from the various offices, and believes that responsive documents will be available for production by the agreed upon deadline.1 The parties have now amicably resolved this dispute and will endeavor to The Government notes that American Casualty's e-mail communications to Government counsel inquiring about the response to the document request were not received because the e-mail address used was incorrect. Plaintiff addressed the messages to [email protected], rather than [email protected]. See Exhibit 2 to Plaintiff's Motion to Compel. Unfortunately, plaintiff elected not to contact Government counsel by telephone when it received no response to its mis-addressed e-mail messages.
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Case 1:06-cv-00354-MBH

Document 14

Filed 02/28/2007

Page 2 of 2

complete discovery without further involvement of the Court, except insofar as it may be necessary to extend the final discovery deadline. Based on the parties' recent discussions and their respective review of the documents previously exchanged between them, the parties believe it may become necessary to request a short extension of the discovery period, and if so, will cooperate in submitting a reasonable request to the Court. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Donald E. Kinner DONALD E. KINNER Assistant Director

s/ Victor G. Klingelhofer Victor G. Klingelhofer, Esq. Cohen Mohr, LLP 1055 Thomas Jefferson St., N.W. Suite 504 Washington, D.C. 20007 Phone (202) 342-2550 Fax (202) 342-6147

s/ Joan M. Stentiford JOAN M. STENTIFORD Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 616-0341 Fax: (202) 514-8624

Attorney for Plaintiff

Attorneys for Defendant