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

Case 1:99-cv-00721-FMA

Document 52

Filed 10/10/2003

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS THE AMERICAN INSURANCE COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 99-721C Judge Allegra

JOINT STATUS REPORT Pursuant to the Court's August 20, 2003 order, the parties file this Joint Status Report to inform the Court of the status of proceedings in this case and to suggest future proceedings. Discovery was completed in this case on October 3, 2003. The parties believe that motions for summary judgment or partial summary judgment may be in order. Accordingly, the parties respectfully request that the Court issue a scheduling order requiring the United States to file its motion for summary judgment on or before December 22, 2003, with the filing of a response to this motion by plaintiff (including the possibility of a cross-motion for partial summary judgement) and a reply thereto to be due as dictated by Rule 7.1(c) of the Rules of the United States Court of Federal Claims. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director

Case 1:99-cv-00721-FMA

Document 52

Filed 10/10/2003

Page 2 of 2

s/Paul T. Devlieger PAUL T. DEVLIEGER Harry R. Blackburn & Associates, P.C. 1610 Spruce Street Philadelphia, PA 19103 (215) 985-0123 ext 103 (215) 985-0124 (fax)

Attorney for Plaintiff

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 (202) 305-7586 (202) 514-7969 (fax) Attorneys for Defendant OF COUNSEL: J. MACKEY IVES Department of the Army Arlington, VA

October 10, 2003