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

Case 1:05-cv-00708-CFL

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Filed 11/27/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

SCOTT TIMBER COMPANY, Plaintiff, v. THE UNITED STATES, Defendant.

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No. 05-708C (Judge Lettow)

JOINT STATUS REPORT Pursuant to the Court's Order filed October 30, 2007, the parties submit this joint status report.

On October 29, 2007, the parties submitted a joint status report informing the Court that the parties were continuing to exchange information and settlement proposals. Plaintiff's last proposal for settlement was submitted to the Government on August 17, 2007. The Government responded with a settlement counter-proposal at 5:35pm on Friday, November 16, 2007. Because of the ensuing Thanksgiving holiday, plaintiff's counsel has not been able to contact authorized plaintiff representatives and engage in a substantive discussion of the Government's counter-proposal until today. Plaintiff intends to respond to the Government's proposal within a week.

Although the time required by each party to analyze and respond to the settlement proposals of the other party has taken somewhat longer than anticipated, the parties continue to 1

Case 1:05-cv-00708-CFL

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believe that settlement of this case is possible. In order to continue the process, the parties request that the Court allow them additional time and amend its order of October 30, 2007 to provide that the time within which the Government may take plaintiff's expert witnesses deposition shall be stayed to and including January 11, 2008, and the parties shall file a joint status report on or before December 27, 2007, informing the Court of the progress of their settlement discussions. If, at that time, the parties believe that settlement is unlikely, the parties request a telephonic status conference at 10:00am on January 15, 2008 to determine an appropriate schedule for resolving this case.

Respectfully submitted,

s/Gary G. Stevens SALTMAN & STEVENS, P.C. 1801 K Street, N.W. Suite M-110 Washington, D.C. 20006 (202) 452-2140 Counsel for Plaintiff

PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

s/Bryant G. Snee BRYANT G. SNEE Deputy Director

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Case 1:05-cv-00708-CFL

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OF COUNSEL: Marcus Wah USDA-OGC, Pacific Region

s/Joan M. Stentiford JOAN M. STENTIFORD Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Phone: (202) 616-0341 Fax: (202) 514-8624 Counsel for Defendant

Dated: November 27, 2007

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