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

Case 1:02-cv-00462-TCW

Document 100

Filed 11/14/2007

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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 Pursuant to the Court's October 16, 2007 Order, Plaintiff, Flint Hills Resources, LP ("Flint Hills"), on behalf of both parties, respectfully submits this Joint Status Report. The Court's Order directed the parties to submit a Joint Status Report addressing the need for a continuation of the stay of proceedings if the matter was not settled before November 14, 2007. The parties have been diligently pursuing settlement discussions and have made substantial progress in reaching agreement to settle the matter. Settlement discussions have been rendered more complicated because of the presence of approximately twenty other similarly situated cases wherein settlement is being collectively pursued together with the present matter. Additional time is needed for the parties to complete these settlement discussions and obtain required approvals for a final settlement agreement. Accordingly, the parties respectfully request that the stay of proceedings be continued for an additional thirty days. With the Court's

Case 1:02-cv-00462-TCW

Document 100

Filed 11/14/2007

Page 2 of 2

concurrence, the parties will file another Joint Status Report within thirty days addressing the need for further proceedings, in the event that the parties have not settled the matter and Flint Hills has not withdrawn its claims before that time.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, Flint Hills Resources LP November 14, 2007

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