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

Case 1:05-cv-01043-VJW

Document 95

Filed 03/28/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS JORGE A. DELPIN-APONTE, et al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-1043C (Judge Wolski)

JOINT STATUS REPORT Pursuant to the Court's order dated March 7, 2008, the parties provide the following joint status report. On March 21, 2008, plaintiffs deposed Ms. Jo Ann Mitchell pursuant to Rule 30(b)(6) of the Rules of this Court. Plaintiffs anticipate seeking leave of the Court to obtain additional discovery, but have not yet determined the scope of that discovery request. As indicated in the Court's order dated January 23, 2008, plaintiffs will promptly discuss this matter with the Government once they have determined the requested scope of additional discovery, to determine if the Government would consent to additional discovery. If the Government opposes that request, plaintiffs will file their motion for leave on or before April 16, 2008.1 In the event that no motion for leave is filed, the parties propose filing a joint status report on April 23, 2008.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director /s/ Mark A. Melnick MARK A. MELNICK Assistant Director

The Court's January 23, 2008 order indicated that any such motion should be filed within ten days of receipt of the transcript. The parties anticipate receiving the deposition transcript on March 31, 2008.

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Case 1:05-cv-01043-VJW

Document 95

Filed 03/28/2008

Page 2 of 2

Of Counsel: DANIEL GARRY Attorney Law Department United States Postal Service 475 L'Enfant Plaza, SW Washington, D.C. 20260 March 28, 2008

/s/ Michael Dierberg MICHAEL DIERBERG Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Class. Unit, 8TH Floor 1100 L Street, N.W. Washington, D.C. 20530 Attorneys for defendant

/s/ Santiago F. Lampón SANTIAGO F. LAMPÓN Lampón & Associates P.O. Box 363641 San Juan, PR 00936-3641 March 28, 2008 Attorneys for plaintiffs

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