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

Case 1:05-cv-01157-LMB

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ______________________________________________________________________________ TAMMERLANE THREE, LIMITED Plaintiff, v. THE UNITED STATES Defendant. ______________________________________________________________________________ File No. 05-1157 (Judge Lawrence M. Baskir)

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 made significant progress in their efforts to settle this matter as well as hundreds of other related cases. Counsel for the parties have held numerous conferences and meetings over the past two months in an attempt to reach final agreement on various settlement terms. These discussions have included lengthy face-to-face meetings held on December 16, 2005, January 17, 2006, and March 1, 2006 in Washington, D.C. The parties have also conducted numerous, and at times daily, telephonic conferences and document exchanges throughout this time period. In connection with these discussions, plaintiffs forwarded to defendant on January 20, 1

Case 1:05-cv-01157-LMB

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2006 a detailed settlement term sheet. The parties are in the process of discussing and revising these terms with the goal of preparing a final settlement agreement that would encompass not only the claims in this matter, but also potentially the claims of more than 600 plaintiffs in more than 230 related cases pending before the Court. The parties are also in the process of drafting numerous other documents that would encompass the terms of their agreement. The parties have also been greatly assisted in their settlement efforts by the involvement of the Alternative Dispute Resolution judge, the Honorable Marian Blank Horn. The parties submitted status reports to the ADR judge on December 19, 2005 and January 11, 2006, and then held in-person conferences with the ADR judge on January 18, 2006, February 13, 2006 and March 6, 2006. In sum, the parties believe that they have made substantial progress in recent months and desire to continue with their efforts to reach an amicable resolution of this matter.

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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: March 14, 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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