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

Case 1:05-cv-00170-LAS

Document 22

Filed 11/17/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

SWANSON GROUP, INC., Plaintiff, v. THE UNITED STATES, Defendant. _____________________________________

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Case No. 05-170C consolidated with 05-171C (Senior Judge Smith)

JOINT PROPOSED PRE-TRIAL SCHEDULE Pursuant to the Court's Order, dated November 3, 2005, the parties submit the following proposed pre-trial schedule based upon the Court's determination to bifurcate the trial of liability from the trial on damages in the instant case: 1. 2. Discovery of liability may commence immediately. The parties shall make initial disclosures on the issue of liability no later than December 20, 2005. All fact discovery on liability shall be completed by May 12, 2006. The parties shall designate experts and exchange expert reports on the issue of liability by June 2, 2006. The parties shall designate rebuttal experts and exchange rebuttal reports on the issue of liability by July 3, 2006. The parties shall depose all experts by August 3, 2006. The parties shall file dispositive motions, if any, no later than September 4, 2006. After the resolution of all dispositive motions, the parties shall contact the Court to schedule a pre-trial conference.

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Case 1:05-cv-00170-LAS

Document 22

Filed 11/17/2005

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Respectfully submitted,

s/Gary G. Stevens SALTMAN & STEVENS P.C. 1801 K Street, N.W. Suite M110 Washington, D.C. 20006 (202) 452-2140 Counsel for Plaintiff

PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director OF COUNSEL: MARCUS R. WAH Associate Regional Attorney USDA-OGC, Pacific Region s/Lindsay E. Williams LINDSAY E. WILLIAMS Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Phone: (202) 353-7995 Fax: (202) 514-8624 Counsel for Defendant

November 17, 2005

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