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

Case 1:05-cv-00708-CFL

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Filed 10/29/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

SCOTT TIMBER, CO. Plaintiff, v. THE UNITED STATES,

Defendant.

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Case No. 05-708C (Judge Lettow)

JOINT STATUS REPORT Pursuant to the Court's Order entered June 7, 2007, the parties submit their joint status report. On June 6, 2007, the parties submitted a joint status report informing the Court that they had begun settlement discussions and those discussions continue to date. To that end, the parties have exchanged various documents for the purpose of negotiating an agreement. The most recent of these documents was sent to the Government by the plaintiff on August 14, 2007. The Government has not yet responded to this proposal, although it intends to and expects to do so in the very near future. Since receiving the proposal, defendant's counsel has conferred with the Forest Service, and with internal reviewing authorities for the purpose of preparing the Government's response to the plaintiff. The Government intends to provide written response to the plaintiff within the week. The parties continue to believe that settlement of this case is possible. In order to continue the process, the parties request the Court's indulgence to allow them additional time, and amend its Order of June 7, 2007, to provide that discovery in this case should be stayed to and including December 7, 2007, and that the parties file a joint status report on or before

Case 1:05-cv-00708-CFL

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November 27, 2007 informing the Court of the progress of settlement discussions. If, at that time, the parties believe that settlement is unlikely, the parties request a telephonic status conference at 10:00 a.m. on November 30, 2007 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 M110 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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OF COUNSEL: Marcus Wah USDA-OCG, 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

October 29, 2007

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CERTIFICATE OF FILING I hereby certify that on this 29th day of October, 2007, a copy of the foregoing

"JOINT STATUS REPORT" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/ Joan M. Stentiford