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

Case 1:05-cv-00457-LJB

Document 19

Filed 05/14/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GEE & JENSEN ENGINEERS, ARCHITECTS & PLANNERS, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-457C (Judge Bush)

JOINT STATUS REPORT Pursuant to the Court's scheduling order, last modified on February 2, 2007 order, the parties respectfully submit this joint status report informing the Court of the parties' progress. Since the Court's last order, the parties have made substantial progress towards completing discovery. The parties have exchanged expert witness reports and deposed their respective expert witnesses. In addition, counsel for Gee & Jensen has deposed four Government witnesses. At this time, counsel for the defendant believes that further discovery is needed. Specifically, counsel for the United States intends to depose three of plaintiffs' witnesses and to propound limited supplemental written discovery. Counsel for the parties are presently conferring to find appropriate dates in the next two months to schedule depositions. Counsel for the United States anticipates that, if depositions are scheduled within the next sixty days, no further enlargements of time from this Court will be necessary. Counsel for Gee & Jensen presently intends to file a motion for summary judgment following the close of discovery. Finally, the parties continue to discuss the possibility of settlement, but have not yet been able to reach a compromise. Accordingly, the parties request additional time, until July 15, 2007, in which to complete remaining discovery and to file a joint

Case 1:05-cv-00457-LJB

Document 19

Filed 05/14/2007

Page 2 of 3

status report with the Court. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director S/Donald E. Kinner DONALD E. KINNER Assistant Director S/William A. Scott WILLIAM A. SCOTT Pedersen & Scott, P.C. 775 St. Andrews Blvd. Charleston, S.C. 29407 Tel: (843) 556-5656 Fax: (843) 556-5635 Attorney for Plaintiff S/Tara K. Hogan TARA K. HOGAN 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) 616-2228 Fax: (202) 305-7643 Attorneys for Defendant May 14, 2007

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Case 1:05-cv-00457-LJB

Document 19

Filed 05/14/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 14th day of May 2007 a copy of the foregoing "JOINT STATUS REPORT" 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. The parties may access this filing through the Court's system.

s/Tara K. Hogan