Free Status Report - District Court of Federal Claims - federal

Case 1:04-cv-00633-ECH

Document 15

Filed 03/30/2005

Page 1 of 2

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 January 6, 2005, plaintiff, HealthAmerica Pennsylvania, Inc. ("HealthAmerica"), and defendant, the United States, file this joint status report. As we stated in our joint status report filed January 3, 2005 and our joint preliminary status report, 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. After the parties agreed to a protective order which was executed by the Court, HealthAmerica provided the Government additional data which has recently been provided to the Government's expert for analysis. Unfortunately, partly due to a change in Government counsel in this case, it took more time than anticipated to provide the data to the Government expert and we now expect that he will require approximately 45 more days to complete his evaluation and analysis of HealthAmerica's claim. Upon the Government's expert's completion of his analysis, the parties expect to continue their settlement negotiations. Accordingly, the parties request until June 3, 2005 to file a status report to inform the Court of the progress of the case.

Case 1:04-cv-00633-ECH

Document 15

Filed 03/30/2005

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 Plaintiffs Dated: March 30, 2005

Attorneys for Defendant

2