Free Memorandum - District Court of Federal Claims - federal

Case 1:04-cv-00497-LMB

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JANELLE HOHNKE, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 04-0497C (Judge Baskir)

JOINT MEMORANDUM Pursuant to the Court's order dated April 19, 2007, the parties respectfully submit the following joint memorandum with suggested dates for pre-trial events.

Witness and Exhibit Lists

Plaintiff shall serve (but not file) a Witness and Exhibit list on May 4, 2007. Defendant shall serve a Witness and Exhibit list on May 11, 2007. Plaintiff shall serve a Memorandum of Contentions of Law on May 17, 2007. Defendant shall serve a Memorandum of Contentions of Law on June 12, 2007. Plaintiff shall serve Proposed Findings of Fact on May 17, 2007. Defendant shall respond to each of the Plaintiff's Proposed Findings of Fact on June 12, 2007. Defendant may propose additional Findings of Fact, to which Plaintiff shall respond by June 19, 2007. The Parties shall file Motions in Limine no later than May 17, 2007. Responses to such

Contentions of Law:

Proposed Findings of Fact

Motions in Limine

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Motions shall be filed no later than June 1, 2007. Replies shall be filed on June 12, 2007. Joint Stipulations The Parties shall file any Procedural Stipulations on June 15, 2007. The Parties shall file a Consolidated Statement setting forth the agreed upon facts and any issues of fact to resolved by the Court by June 21, 2007. The Parties shall file a Consolidated Statement setting forth their contentions of law by June 21, 2007. In preparing the Consolidated Statements, the Parties' attention is directed to the Court's Special Procedures Order. The Parties shall file a Joint Trial Exhibit List on June 21, 2007. The Parties shall file a Joint Trial Witness List on June 21, 2007. For each witness, the parties shall set forth the witnesses' name and address, the amount of proposed time the witness will testify on direct examination, the title and/or job description of the witness, and proposed topics of testimony. The final Pre-Trial Conference (telephonic) will take place on July 5, 2007. The Trial schedule, including certain time limitations, will be set at the Pre-Trial Conference. The schedule for Post-Trial Briefing shall also be set at this conference.

Consolidated Statement of Contentions of Fact

Consolidated Statement of Contentions of Law

Joint Trial Exhibit List

Joint Trial Witness List

Pre-Trial Conference

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Case 1:04-cv-00497-LMB

Document 62

Filed 05/03/2007

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s/Brenda Lewison BRENDA LEWISON Law Office of Arthur Heitzer 633 West Wisconsin Avenue Suite 1410 Milwaukee, WI 53203 (414) 273-1040

PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/Mark A. Melnick MARK A. MELNICK Assistant Director

s/Michael N. O'Connell MICHAEL N. O'CONNELL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit Washington, D.C. 20530 (202) 353-1618 (202) 514-8624 (fax) Date: May 3, 2007

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