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

Case 1:05-cv-00563-LMB

Document 17

Filed 02/28/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS COLLINS NATIONAL, a limited partnership, and COLLINS DEVELOPMENT CO., a California corporation as General Partner, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 05-563C (Judge Baskir)

JOINT STATUS REPORT Pursuant to the Court's order dated December 7, 2005, the parties respectfully submit the following joint status report. The parties have responded to the written discovery requests propounded by the other party. The parties agree to reserve any objections to the sufficiency of the discovery responses and any filing of motions to compel, if necessary, until a later date to be determined by the court. At this time, the Government believes that a partial summary judgment motion related to the liability for abatement of the asbestos could be beneficial to the expeditious resolution of this matter. While the plaintiffs disagree that a summary judgment motion at this time would be beneficial, the parties are willing to propose the following briefing schedule: March 29, 2006 April 26, 2006 May 10, 2006 Defendant's Summary Judgment Motion due Plaintiff's Response due Defendant's Reply due

The parties agree to provide a courtesy copy of the briefs via facsimile or electronic mail.

Case 1:05-cv-00563-LMB

Document 17

Filed 02/28/2006

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

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

s/ David Taylor DAVID TAYLOR, ESQ. Tighe Patton Armstrong Teasdale, PLLC 1747 Pennsylvania Ave., N.W. Suite 300 Washington, D.C. 20007 Tel: (202) 454-2855 Fax: (202) 454-2805 Attorney for Plaintiffs

s/ Nancy M. Kim NANCY M. KIM Trial Attorney Commercial Litigation Civil Division U.S. Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 353-0546 Fax: (202) 514-8640 Attorneys for Defendant

February 28, 2006

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