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

Case 1:05-cv-00503-TCW

Document 46

Filed 01/04/2008

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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 October 1, 2007, Order, the parties file this joint status report. Over the past three months, the parties have been discussing the possibility of stipulating to the factual questions that remain in this case. The parties have made substantial progress toward that goal but are not ready to enter a stipulation at this time. Accordingly, the parties propose that the Court leave in place the current stay for an additional thirty days. If the Court adopts this proposal, then the parties would file another joint status report on or before February 4, 2008, either updating the Court on the parties' negotiations or proposing a pretrial schedule. If the parties reach an impasse before February 4, 2008, 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.

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Case 1:05-cv-00503-TCW

Document 46

Filed 01/04/2008

Page 2 of 2

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 RICHARD T. MORRISON Acting Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section W.C. RAPP Senior Trial Attorney January 4, 2008 Date /s W.C. Rapp Of Counsel

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