Case 1:05-cv-00503-TCW
Document 52
Filed 06/03/2008
Page 1 of 2
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
HOSPITAL SERVICE ASSOCIATION OF NORTHEASTERN PENNSYLVANIA, Plaintiff, v. THE UNITED STATES, Defendant.
) ) ) ) ) No. 05-503 T ) (Judge Wheeler) ) ) ) )
JOINT STATUS REPORT Pursuant to the Court's April 7, 2008, Order, the parties file this joint status report. As explained in the joint status report filed on February 4, 2008, the parties reached an agreement with respect to the computation of the loss deductions that would result from the Court's September 14, 2007, Opinion and Order. On March 21, 2008, plaintiff submitted to defendant a proposed computation of the overpayment that would result from those deductions. At the same time, plaintiff brought to the attention of defendant's attorneys certain collateral matters that might affect the computation of the refund. Since the parties submitted their last status report on April 4, 2008, they have been discussing the collateral matters in an effort to resolve them without the Court's intervention. Such discussions have taken longer than anticipated. If the parties resolve the collateral matters, defendant will still need several weeks to review plaintiff's proposed computations. The parties therefore propose that the Court maintain the current stay of proceedings for an additional sixty days to allow the parties to continue their efforts to stipulate to the
Case 1:05-cv-00503-TCW
Document 52
Filed 06/03/2008
Page 2 of 2
computation of the overpayment that would result from the Court's September 14, 2007, Opinion and Order. If the Court adopts this proposal, then the parties will file another joint status report on or before August 4, 2008. If the parties reach a stipulation or an impasse before that date, then the parties will notify the Court at such earlier time. Counsel for plaintiff has consented to the filing of this Joint Status Report by defendant's attorney of record. Respectfully submitted,
/s Karen Servidea KAREN SERVIDEA Attorney of Record U.S. Department of Justice Tax Division Court of Federal Claims Section Post Office Box 26 Ben Franklin Post Office Washington, D.C. 20044 (202) 616-3423 Counsel for Defendant NATHAN J. HOCHMAN Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section W.C. RAPP Senior Trial Attorney June 3, 2008 Date /s W. C. Rapp Of Counsel