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

Case 1:04-cv-00633-ECH

Document 17

Filed 06/02/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS HEALTHAMERICA PENNSYLVANIA, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 04-633C (Judge Hewitt)

JOINT STATUS REPORT Pursuant to the Court's order dated April 11, 2005, plaintiff, HealthAmerica Pennsylvania, Inc. ("HealthAmerica"), and defendant, the United States, file this joint status report. As we stated in our prior joint status reports, the parties have agreed to voluntarily exchange information and defer discovery in order to facilitate settlement discussions. HealthAmerica has provided the United States with copies of reports which support its claim and has supplemented those reports with additional data after the Court executed the protective order in this case. The Government's expert has conducted his initial evaluation of plaintiff's data and has requested additional information from plaintiff's consultants so that he may better evaluate the relevant reports. The parties agree that a further exchange of information and expert analysis may prove helpful to subsequent settlement negotiations. Under these circumstances, the parties need additional time to conduct the settlement negotiations. The parties, therefore, respectfully request until September 2, 2005 to file a status report to inform the Court of the progress of the case.

Case 1:04-cv-00633-ECH

Document 17

Filed 06/02/2005

Page 2 of 2

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director

s/ Arthur N. Lerner ARTHUR N. LERNER Crowell & Moring, LLP 1001 Pennsylvania Ave., N.W. Washington, D.C. 20004 Tel: 202-624-2500 Fax: 202-628-5116 E-mail: [email protected]

s/ J. Reid Prouty J. REID PROUTY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7585 Fax: (202) 514-7969 E-mail: [email protected] OF COUNSEL: JILL GERSTENFIELD Office of the General Counsel Office of Personnel Management 1900 E Street, N.W. Washington, D.C. 20415

Attorneys for Plaintiff

Attorneys for Defendant

Dated: June 2, 2005