Free Status Report - District Court of Federal Claims - federal

Case 1:05-cv-00468-TCW

Document 18

Filed 05/31/2006

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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 AND MOTION TO ENLARGE STAY Pursuant to the Parties Joint Status Report dated March 31, 2006, plaintiff, American States Insurance Company submits the following status report on behalf of both parties. On May 26, 2006, Counsel for Plaintiff provided counsel for Defendant with an offer of settlement. Counsel for the Defendant

is seeking authority to accept Plaintiff's settlement offer. With this development, counsel for the parties jointly request that the Court allow the stay to remain in effect until July 15, 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 July 15, 2006.

Case 1:05-cv-00468-TCW

Document 18

Filed 05/31/2006

Page 2 of 2

Respectfully submitted, AMERICAN STATES INSURANCE CO. By:/s/ Harold E. 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 May 31, 2006

CERTIFICATE OF FILING I hereby certify that on May 31, 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. system. Parties may access this filing through the Court's

/s/ Harold E. McKee