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

Case 1:04-cv-00633-ECH

Document 10

Filed 01/03/2005

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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 September 2, 2004, plaintiff, HealthAmerica Pennsylvania, Inc. ("HealthAmerica"), and defendant, the United States, file this joint status report. As we stated in 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 that support its claim. In addition, an outside expert has been retained by the United States in mid-December 2004 to evaluate the information provided by HealthAmerica. To date, the Government's expert has reviewed HealthAmerica's claim and complaint, has evaluated reports prepared by HealthAmerica's consultants, and will soon begin to analyze additional data to be provided by HealthAmerica. Defendant's expert will require until at least until April 4, 2005 to complete his evaluation and analysis of HealthAmerica's claim. Upon defendant's expert's completion of his analysis, the parties expect to continue their settlement negotiations. Accordingly, the parties request until April 4, 2005 to file a status report to inform the Court of the progress of the case.

Case 1:04-cv-00633-ECH

Document 10

Filed 01/03/2005

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 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/ Carolyn J. Craig CAROLYN J. CRAIG 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) 305-7561 Fax: (202) 305-7644 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: January 3, 2005

Attorneys for Defendant

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