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

Case 1:05-cv-00468-TCW

Document 33

Filed 02/01/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS AMERICAN STATES INSURANCE CO., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-468C (Judge Wheeler)

JOINT STATUS REPORT AND MOTION TO ENLARGE STAY Pursuant to the Court's order dated January 3, 2007, the parties respectfully submit the following joint status report and request that the Court enlarge the stay in this case for an additional 60 days, through and including April 3, 2007, to afford the parties time for the General Services Administration ("GSA") to process payment of the settlement amount. Previously, the parties reached a settlement of this matter and have executed a settlement agreement. Pursuant to the settlement agreement, American States Insurance Company ("American States") has submitted both a release and invoice to the GSA for processing and payment. However, the GSA has certain internal administrative requirements that must be met by American States prior to the payment of the agreed-upon settlement amount. Representatives of American States are working with the GSA to meet those internal requirements. Additional time is needed for the parties to work through the administrative procedures established and for the GSA to process payment of the settlement amount. For the foregoing reasons, the parties respectfully request that the Court grant this joint motion to stay proceedings in this case for 60 days, through and including April 3, 2007, for the GSA to process payment of the settlement amount and for the parties to execute a joint stipulation for dismissal.

Case 1:05-cv-00468-TCW

Document 33

Filed 02/01/2007

Page 2 of 2

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

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

s/ Harold McKee HAROLD MCKEE Riordan, Donnelly, Lipinski & McKee, Ltd. 10 North Dearborn Street, 4th Floor Chicago, IL 60602 Tel: (312) 663-9400 Fax: (312) 663-1028 Attorney for Plaintiff

s/ Nancy M. Kim NANCY M. KIM Trial Attorney Commercial Litigation Branch Civil Division 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 1, 2007