Free Response to Motion - District Court of Federal Claims - federal

Case 1:05-cv-00114-EJD

Document 21

Filed 03/09/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

A.A.B JOINT VENTURE Plaintiff, v. THE UNITED STATES OF AMERICA Defendants.

) ) ) ) ) ) ) ) ) )

Case Nos. 04-1719C, 05-114C, 05-1172C & 06-49C Judge Damich

MEMORANDUM IN RESPONSE TO DEFENDANT'S MOTION TO CONSOLIDATE Plaintiff A.A.B Joint Venture, in response to the Motion to Consolidate filed by the United States, states and represents as follows: Plaintiff has no objection to the consolidation of Case Nos. 05-114C, 05-1172C and 06-49C. Defendant's counsel will shortly submit a proposed schedule for these three proposed consolidated cases. With respect to Case No. 04-1719, the parties have agreed not to pursue consolidation of 04-1719 with the other, aforementioned cases. Defendant's counsel will be submitting a proposed amendment to the existing Scheduling Order that sets forth a independent, revised schedule for that matter. Respectfully submitted,

__/s/ Brian Cohen_______________ Brian Cohen BELL BOYD & LLOYD, PLLC 1615 L Street N.W., Suite 1200 Washington, D.C. 20036 (202) 466-6300

90302/F/2

Case 1:05-cv-00114-EJD

Document 21

Filed 03/09/2006

Page 2 of 2

CERTIFICATE OF SERVICE In addition to the electronic copy which is automatically sent to opposing counsel by the Court, I hereby certify that a paper copy of the foregoing filing was served by mail on counsel for the United States, addressed as follows:

Shalom Brilliant, Esq. Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit, 8th Floor Washington, D.C. 20530

this 9th day of March, 2006.

___/s/ Brian Cohen___________

2