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

Case 1:06-cv-00354-MBH

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Filed 09/06/2006

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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 June 15, 2006, the parties report that they have completed initial disclosures and document exchange, and following their review of the exchanged documents, the parties intend to meet to discuss this option. Plaintiff continues to believe that non-binding mediation would be helpful in reaching a settlement. The parties previously submitted a Joint Preliminary Status Report in which they proposed a discovery and briefing schedule which they believe meets the Court's requirement that they propose a schedule, with dates, for resolution of the case. That schedule is repeated here, for the Court's convenience: A. All discovery commenced in time to be completed by February 28, 2007. Maximum of 25 interrogatories by each party to any other party. Responses due 30 days after service. Maximum of 25 requests for admission by each party to any other party. Responses due 30 days after service. Maximum of 5 depositions by plaintiff and 5 by defendant. Each deposition is limited to maximum of 8 hours. Reports from retained experts under Rule 26(a)(2) due: i. from plaintiff by December 1, 2006. ii. from defendant by January 15, 2007.

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F. G.

The parties request a pretrial conference on or around May 1, 2007. All potentially dispositive motions should be filed on or before March 28, 2007. Final lists of witnesses and exhibits under Rule 26(a)(3) should be due, if necessary, no later than 30 days after resolution of all dispositive motions. Parties should have 30 days after service of final lists of witnesses and exhibits to list objections under Rule 26(a)(3). Time of trial shall be evaluated at the pre-trial conference.

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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

Case 1:06-cv-00354-MBH

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Filed 09/06/2006

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