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

Case 1:05-cv-01185-MCW

Document 19

Filed 09/08/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS GARY NOLAN, et. al, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-1185C (Judge Williams)

JOINT STATUS REPORT Pursuant to the Court's order dated July 13, 2006, the parties respectfully submit the following joint status report. On May 25, 2006, plaintiffs forwarded a settlement offer to the undersigned counsel for defendant. Since then, the parties have been attempting to negotiate a mutual resolution of this matter without the need for further litigation. In this regard, the parties have made efforts to collect the necessary information to further settlement efforts, such as the number of hours of overtime the plaintiffs have worked, the amount of overtime that is owed plaintiffs, calculations showing how the amount of overtime was calculated, the amount of overtime that have already been paid to some plaintiffs, and when those payments were made. The parties have additional questions on the information provided by the agency's personnel office and believe that additional time would help the parties negotiate a settlement that would be mutually acceptable to both parties. The parties, therefore, request that the Court continue to stay proceedings in this case. The counsel for the parties propose to submit another joint status report on or before October 20, 2006, if the case is not settled by that time, setting forth the progress the parties have made in resolving this matter.

Case 1:05-cv-01185-MCW

Document 19

Filed 09/08/2006

Page 2 of 2

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/ Todd M. Hughes TODD M. HUGHES Assistant Director

s/ David Ricksecker GREGORY K. MCGILLIVARY DAVID RICKSECKER Woodley & McGillivary 1125 15th Street, N.W., Suite 400 Washington, D.C. 20005 Tel: (202) 833-8855 Fax: (202) 452-1090 Attorneys for Plaintiffs

s/ Nancy M. Kim NANCY M. KIM Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 353-0546 Fax: (202) 514-8640 Attorneys for Defendant

September 8, 2006