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

Case 1:05-cv-00528-LMB

Document 35

Filed 06/23/2006

Page 1 of 5

IN THE UNITED STATES COURT OF FEDERAL CLAIMS TELENOR SATELLITE SERVICES, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-528C (Judge Baskir)

JOINT STATUS REPORT Pursuant to the Court's June 2, 2006 Order, the parties submit this Joint Status Report. Plaintiff's Statement: Having been informed by the Government that it does not wish to discuss settlement, Plaintiff reports that this case should proceed rapidly to discovery and trial. Plaintiff does not anticipate lengthy discovery. Plaintiff, therefore, proposes the following schedule for further proceedings: September 15, 2006 October 15, 2006 Trial Completion of all discovery

Case 1:05-cv-00528-LMB

Document 35

Filed 06/23/2006

Page 2 of 5

Plaintiff proposes that all other deadlines, including those for pretrial submissions, be governed by the Rules of the United States Court of Federal Claims. Plaintiff expects that a trial of this matter would be concluded within three days of its commencement, and requests that any trial be held in Washington, D.C. Defendant's Statement: Defendant reports that we have informed plaintiff that we will consider any written settlement proposal that plaintiff makes. Defendant also reports that this case should proceed to discovery, any further dispositive motions, and preparation for trial. Defendant expects to file a dispositive motion upon the issue of whether plaintiff could have avoided the costs that it seeks. Defendant, therefore, proposes the following schedule for further proceedings: September 30, 2006 October 31, 2006 February 2007 Completion of discovery; Filing of any dispositive motions; Trial, if necessary.

Case 1:05-cv-00528-LMB

Document 35

Filed 06/23/2006

Page 3 of 5

Defendant proposes that all other deadlines, including those for pretrial submissions, be governed by the Rules of the United States Court of Federal Claims. Defendant expects that a trial of this matter would be concluded within three days of its commencement, and requests that any trial be held in Washington, D.C. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Patricia M. McCarthy by s/ Brian M. Simkin PATRICIA M. MCCARTHY Assistant Director s/ Frederick W. Claybrook, Jr. FREDERICK W. CLAYBROOK, JR. Crowell & Moring LLP 1001 Penn. Ave., N.W. Washington, D.C. 20004-2595 (202) 624-2500 Attorney for Plaintiff June 23, 2006 s/Timothy P. McIlmail TIMOTHY P. MCILMAIL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Telephone: (202) 514-4325 Facsimile: (202) 514-7965

-3-

Case 1:05-cv-00528-LMB

Document 35

Filed 06/23/2006

Page 4 of 5

OF COUNSEL: ONA M. HAHS Attorney-Adviser Department of State Attorneys for Defendant June 22, 2006

Case 1:05-cv-00528-LMB

Document 35

Filed 06/23/2006

Page 5 of 5

Certificate of Filing I hereby certify that on June 23, 2006, 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.