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

Case 1:06-cv-00099-LB

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) _________________________________) INFORMATION SYSTEMS & NETWORKS CORPORATION,

No. 06-99C (Judge Block)

JOINT STATUS REPORT Plaintiff, Information Systems and Networks Corporation ("Plaintiff" or "ISN"), and defendant, the United States, by their undersigned attorneys, file this Joint Status Report pursuant to this Court's Order dated May 20, 2008. 1. Pending Motions

There are currently pending before the Court three motions: (1) ISN's Motion In Limine To Establish As Admitted

All Costs Incurred By ISN As Set Forth In The Defendant's Audit Reports And Final Decision (briefing concluded); (2) ISN's Motion For A Protective Order And In Limine

To Prevent The Testimony Of Defendant's Proposed Expert, Ellen E. Erdelsky (briefing not concluded: subject to Court approval, the parties have agreed to an extension of defendant's response date to July 14, 2008, and of ISN's reply date to August 14, 2008); and (3) ISN's Motion To Amend Complaint (briefing not

concluded).

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2.

Discovery Both fact and expert discovery have been completed,

with one exception.

Defendant has noticed the deposition of

ISN's President and Chief Executive Officer, whom, plaintiff has informed defendant, has been out of the country and unavailable. The parties will work to complete her deposition when she becomes available. 3. Schedule Under Case Management Procedure Plaintiff's Statement: ISN requests the Court to enter an Order consistent with the requirements of RCFC Appendix A, Case Management Procedures, setting forth the following proposed dates: 1. 2. 3. 4. Trial: February 16, 2009 (Washington, D.C.) January 28, 2009

Final Pretrial Conference: Meeting of Counsel:

December 1, 2008

Plaintiff's Memorandum of Contentions of Fact and Law: December 9, 2008

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Defendant's Memorandum of Contentions of Fact and Law: January 7, 2009

Defendant's Statement: Defendant anticipates that this case will have to be tried and that no more than four days will be required for trial of the entire case. Defendant requests that trial be scheduled to take

place in October or November, 2008, in Washington, D.C., and that the timing of the parties' pretrial activities be governed by the

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time limits set forth in Appendix A §§ 13-17.

If the Court

cannot schedule trial for October or November, 2008, defendant requests a final pretrial conference on January 28, 2009, and that trial commence the week of February 16, 2009 (February 16 itself, however, is President's Day, a Federal holiday). Respectfully submitted,

GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director

s/Mark A. Melnick by s/Brian M. Simkin MARK A. MELNICK Assistant Director

s/Norman H. Singer NORMAN H. SINGER Singer & Associates, P.C. 10411 Motor City Drive 7th Floor Bethesda, MD 20817 Telephone: (240) 395-2343 Facsimile: (301) 469-0403 Attorney for Plaintiff June , 2008

s/Timothy P. McIlmail TIMOTHY P. MCILMAIL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Telephone: (202) 616-0342 Facsimile: (202) 514-7965 OF COUNSEL: GREGORY T. ALLEN Trial Attorney Defense Contract Management Agency Manassas, VA Attorneys for Defendant June , 2008

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Certificate of Filing I hereby certify that on June , 2008, a copy of the I

foregoing Joint Status Report was filed electronically.

understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. may access this filing through the Court's system. Parties

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