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

Case 1:05-cv-00503-TCW

Document 50

Filed 04/04/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS HOSPITAL SERVICE ASSOCIATION OF NORTHEASTERN PENNSYLVANIA, Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) ) ) )

Civil Action No. 05-503 T Judge Thomas C. Wheeler

JOINT STATUS REPORT Pursuant to the Court's February 5, 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. Also on that date, plaintiff brought to the attention of defendant's attorneys certain collateral matters that might affect the computation of the refund. Defendant has started to review plaintiff's proposed computation but will need additional time to complete its review. 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 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 June 3, 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 defendant has consented to the filing of this Joint Status Report by plaintiff's 1

Case 1:05-cv-00503-TCW

Document 50

Filed 04/04/2008

Page 2 of 2

attorney of record. Respectfully submitted, ____/s/ Frederick H. Robinson _____ Frederick H. Robinson MILLER & CHEVALIER CHARTERED 655 Fifteenth Street, N.W. Suite 900 Washington, D.C. 20005 (202) 626-5800 (202) 628-0858 (facsimile) Counsel of Record for Plaintiff Of Counsel: Maria O. Jones Adam P. Feinberg MILLER & CHEVALIER CHARTERED 655 Fifteenth Street, N.W. Suite 900 Washington, D.C. 20005 (202) 626-5800 (202) 628-0858 (facsimile) Dated: April 4, 2008

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