Free Status Report - District Court of Federal Claims - federal

Case 1:05-cv-00468-TCW

Document 20

Filed 07/17/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

AMERICAN STATES INSURANCE COMPANY, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 05-468C (Judge Wheeler)

PLAINTIFF'S STATUS REPORT UPON BEHALF OF BOTH PARTIES AND MOTION TO ENLARGE STAY

Pursuant to the Court's Order dated May 31, 2006, Plaintiff, American States Insurance Company, submits the following joint status report and requests that the Court enlarge the stay entered in this case by thirty (30) days, to and including August 16, 2006. On May 26, 2006, Counsel for Plaintiff provided counsel for Defendant with a settlement demand. Counsel for the Defendant is seeking authority to accept Plaintiff's settlement demand. Counsel for the parties believe they will be able to effectuate a potential settlement within fourteen (14) days. With this development, counsel for the parties jointly request that the Court allow the stay to remain in effect until August 16, 2006 in order for counsel for the Defendant to obtain settlement authority and for counsel to draft a settlement agreement memorializing all the terms of the settlement. For this reason, both parties respectfully request that the Court continue the stay of this case through August 16, 2006.

Case 1:05-cv-00468-TCW

Document 20

Filed 07/17/2006

Page 2 of 2

Respectfully submitted,

AMERICAN STATES INSURANCE COMPANY

By: /s/ Harold E. McKee

Harold E. McKee Riordan, Donnelly, Lipinski & McKee, Ltd. 10 N. Dearborn St., 4th Floor Chicago, IL 60602 Tel: (312) 663-9400 Fax: (312) 663-1028

CERTIFICATE OF FILING I hereby certify that on July 17, 2006, a copy of the foregoing "Plaintiff's Status Report and Motion" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. /s/ Harold E. McKee