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

Case 1:05-cv-01157-LMB

Document 12

Filed 05/15/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ______________________________________________________________________________

TAMMERLANE THREE, LIMITED

Plaintiff, v. THE UNITED STATES

File No. 05-1157 (Judge Lawrence M. Baskir)

Defendant. ______________________________________________________________________________ JOINT STATUS REPORT Pursuant to the Court's Order of January 12, 2006, the parties respectfully submit the following Joint Status Report to apprise the Court of the status of their continuing efforts to resolve this and numerous closely-related cases through the Court's Alternative Dispute Resolution ("ADR") pilot program. The parties are pleased to report that they have resolved all principal issues and the attorneys for both sides have reached a proposed settlement agreement, subject to final approval by both parties. This settlement agreement, which was reached during the ADR conferences held before Judge Horn on May 8 through 9, 2006, is the product of the parties' efforts through the ADR process over the past eighteen months. The parties' agreement encompasses over 250 Section 515 prepayment cases pending before the Court involving more than 800 plaintiffs ­ including this case. The parties expect to finalize the various documents that comprise the terms of their agreement by May 26, 2006 and begin the approval process within the Department of Justice by

Case 1:05-cv-01157-LMB

Document 12

Filed 05/15/2006

Page 2 of 2

June 23, 2006. Thus, the parties request that this matter continue to be stayed while the agreement goes through the relevant approval process on both sides. The parties will report to the Court once the approval process is complete.

Respectfully submitted, s/ Jeff H. Eckland JEFF H. ECKLAND Mark J. Blando, Of Counsel ECKLAND & BLANDO LLP 500 Lumber Exchange 10 South Fifth Street Minneapolis, Minnesota 55402 Telephone: (612) 236-0160 Facsimile: (612) 236-0179 Jerry W. Snider, Of Counsel William L. Roberts, Of Counsel Mark D. Savin, Of Counsel FAEGRE & BENSON LLP 2200 Wells Fargo Center Minneapolis, MN 55402 Telephone: (612) 766-7000 Facsimile: (612) 766-1600 Attorneys for Plaintiffs Dated: May 15, 2006 Filed Electronically With the consent of the Attorney for Defendant PETER D. KEISLER Assistant Attorney General s/ David M. Cohen DAVID M. COHEN Director s/ Shalom Brilliant SHALOM BRILLIANT Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit Room 8012 Washington, D.C. 20530 Telephone: (202) 305-7561 Facsimile: (202) 305-7643 Attorneys for Defendant

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