Free Status Report - District Court of Federal Claims - federal

Case 1:05-cv-00608-ECH

Document 39

Filed 09/01/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS FRANCISCO JAVIER RIVERA AGREDANO, ) ) ) ) ) ) ) ) ) )

Electronic Filing No. 05-608C (Judge Hewitt) (ADR Judge Bruggink)

Plaintiff, v. THE UNITED STATES, Defendant.

DEFENDANT'S STATUS REPORT Pursuant to Judge Bruggink's instruction during the telephonic ADR hearing held on August 11, 2006, defendant, the United States, submits this ADR Status Report. We have contacted plaintiff's counsel, and she fully concurs with the contents of this report. The parties have not made any progress toward resolving this case in the last three weeks, and do not anticipate reaching a successful resolution before the end of September. The parties therefore request that this ADR proceeding be suspended while the parties pursue formal discovery. The Scheduling Order in this case requires the parties to complete discovery on or before December 22, 2006. The parties expect that they will be in a better position to reevaluate their respective positions at that time. Respectfully submitted,

PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Patricica M. McCarthy PATRICIA M. McCARTHY Assistant Director

Case 1:05-cv-00608-ECH

Document 39

Filed 09/01/2006

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s/ Devin A. Wolak DEVIN A. WOLAK Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit, 8th Floor Washington, DC 20530 Tel. (202) 616-0170 Fax (202) 514-8624 Attorneys for Defendant

September 1, 2006

2

Case 1:05-cv-00608-ECH

Document 39

Filed 09/01/2006

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CERTIFICATE OF FILING I hereby certify that on September 1, 2006, a copy of the foregoing "ADR 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/ Devin A. Wolak DEVIN A. WOLAK