Free Status Report - District Court of Federal Claims - federal

Case 1:06-cv-00101-FMA

Document 24

Filed 08/31/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JAY CASHMAN, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-101C (Judge Allegra)

JOINT STATUS REPORT Pursuant to the Court's Order of June 21, 2007, the parties respectfully submit this joint status report. The parties completed fact discovery on August 17, 2007. The parties are in the process of scheduling another meeting to engage in settlement discussions in light of the information obtained through the completion of fact discovery, and continue to hope that they will be able to reach an agreement and resolve this litigation amicably. In the event that the parties are not able to reach an agreement, the parties intend to file cross motions for summary judgment on the issue of entitlement. The parties propose that any motions for summary judgment be filed on or before November 16, 2007. The parties also propose that the parties would designate experts following the Court's decision on the parties' motions for summary judgment, so that the parties are advised of the remaining issues in the case prior to designating their experts, and at that time schedule the completion of all discovery. However, if the parties are able to reach an agreement in principle, the parties may file a motion to stay the case while the settlement is reviewed by an authorized representative of the Attorney General.

Case 1:06-cv-00101-FMA

Document 24

Filed 08/31/2007

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

__s/ Michael H. Payne_______ Michael H. Payne Payne Hackenbracht & Sullivan 220 Commerce Dr., Suite 100 Fort Washington, PA 19034 (215) 542-2777 Fax: (215) 542-2779

s/ Donald E. Kinner DONALD E. KINNER Assistant Director

s/ Tara Kilfoyle TARA KILFOYLE Trial Attorney Commercial Litigation Branch Civil Division 1100 L St., N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 305-1709 Fax: (202) 307-0972

August 31, 2007

Case 1:06-cv-00101-FMA

Document 24

Filed 08/31/2007

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CERTIFICATE OF SERVICE I hereby certify that on August 31, 2007 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/ Tara J. Kilfoyle TARA J. KILFOYLE