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

Case 1:06-cv-00101-FMA

Document 20

Filed 06/01/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

JAY CASHMAN, INC., Plaintiff, v. THE UNITED STATES, Defendant.

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No. 06-101C (Judge Allegra)

JOINT STATUS REPORT Pursuant to the Court's Order of May 2, 2007, the parties respectfully submit this Joint Status Report. The parties have met upon two occasions to engage in settlement negotiations since the parties' status conference with the Court on May 1, 2007. On May 15, 2007, counsel for defendant met with counsel for plaintiff at counsel for plaintiff's offices in Fort Washington, Pennsylvania. On May 22, 2007, counsel for the parties and representatives from Jay Cashman, Inc. and the Army Corps of Engineers met at defendant's offices in Caven Point, New Jersey. Although the parties have made progress in their negotiations, to date, the parties have not been able to reach an agreement. However, at this time, both parties wish to continue to explore the possibility of settlement. The parties plan to meet again on June 13, 2007, at defendant's offices in Caven Point, New Jersey, for further settlement negotiations. The parties respectfully propose that pursuant to the Court's Order of May 2, 2007, the parties submit an additional Joint Status Report on or before June 29, 2007, advising the Court of their further progress, if neither party has filed a motion to lift the stay prior to that time.

Case 1:06-cv-00101-FMA

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Filed 06/01/2007

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Respectfully submitted, s/ Michael H. Payne MICHAEL H. PAYNE Payne Hackenbracht & Sullivan 220 Commerce Dr., Suite 100 Fort Washington, PA 19034 Tele: (215) 542-2777 Fax: (215) 542-2779 Attorney for Plaintiff PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

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 Attorneys for Defendant

June 1, 2007

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Case 1:06-cv-00101-FMA

Document 20

Filed 06/01/2007

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CERTIFICATE OF SERVICE I hereby certify that on this 1st day of June 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. The parties may access this filing through the Court's system.

s/ Tara Kilfoyle