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

Case 1:05-cv-00468-TCW

Document 27

Filed 10/13/2006

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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 September 8, 2006, the parties respectfully submit the following joint status report and request that the Court enlarge the stay in this case for an additional 21 days, through and including November 7, 2006, to afford the Government time to obtain approval from the authorized representative of the Attorney General to accept plaintiff's settlement offer and, if appropriate, to enter into a settlement agreement. On May 26, 2006, counsel for plaintiff provided defendant with a formal offer of settlement. On October 11, 2006, the interested agency, the General Services Administration, provided a written memorandum recommending that the United States accept plaintiff's settlement offer. Additional time is needed for the undersigned counsel for defendant to obtain approval from the authorized representative of the Attorney General to accept plaintiff's settlement offer and, if appropriate, enter into a settlement agreement. For the foregoing reasons, the parties respectfully request that the Court grant this joint motion to stay proceedings in this case for 21 days, through and including November 7, 2006, for the parties to continue their efforts to resolve this case without the need for further litigation.

Case 1:05-cv-00468-TCW

Document 27

Filed 10/13/2006

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

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

s/ Harold E. McKee HAROLD E. 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

October 13, 2006