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

Case 1:02-cv-00462-TCW

Document 98

Filed 10/15/2007

Page 1 of 1

IN THE UNITED STATES COURT OF FEDERAL CLAIMS FLINT HILLS RESOURCES, LP, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 02-462C (Judge Wheeler)

JOINT STATUS REPORT Plaintiff, Flint Hills Resources, LP ("Flint Hills"), on behalf of both parties, respectfully submits this Joint Status Report. The Court's October 3, 2007 Order directed the parties to submit a Joint Status Report addressing the need for a continuation of the stay of proceedings in light of ConocoPhillips v. United States, 2007 WL 2741200 (Fed. Cir. Sept. 21, 2007). Following the decision in ConocoPhillips, Flint Hills submitted an offer of settlement to the government proposing to withdraw its claims pursuant to a mutual release of the parties. The government is evaluating Flint Hills' offer. Accordingly, the parties respectfully request that the stay of proceedings be continued for an additional thirty days to permit the parties to seek to resolve this matter. With the Court's concurrence, the parties will file another Joint Status Report within thirty days addressing the need for further proceedings, in the event that Flint Hills has not withdrawn its claims before that time. Respectfully submitted, s/ J. Keith Burt J. Keith Burt Mayer, Brown LLP 1909 K Street, N.W. Washington, DC 20006 (202) 263-3208 (phone) (202) 263-5208 (fax) Attorneys for Plaintiff

October 15, 2007