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

Case 1:98-cv-00868-FMA

Document 82

Filed 11/12/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS L.P. CONSULTING GROUP, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 98-868C (Judge Allegra)

PARTIES' JOINT STATUS REPORT Pursuant to the Court's order dated August 9, 2004, the parties file this joint status report. Plaintiff's deposition of Plaintiff's

Carl Puricelli was completed on August 10, 2004.

Rule 30(b)(6) deposition was completed on October 21, 2004. At the hearing on August 9, 2004, defendant notified the Court that it would proceed by filing a dispositive motion. Previously, on January 27, 2000, the Court had denied defendant's motion for partial summary judgment without prejudice. The Court

directed that dispositive motions should be filed after the completion of discovery. The parties propose the following schedule for the submission of dispositive motions: December 23, 2004 Defendant's Motion For Summary Judgment 1

1 Defendant's counsel amongst other things is on travel on November 29 - December 1, 2004, for previously scheduled depositions in Aaron v. United States, No. 00-315C and consolidated cases. Defendant's counsel recently was reassigned to Flour Hanford v. United States , Fed. Cl. Nos. 02-759, 03-1287, and must present oral argument in that matter on December 10, 2004.

Case 1:98-cv-00868-FMA

Document 82

Filed 11/12/2004

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January 28, 2005

Plaintiff's Response To Defendant's Motion For Summary Judgment (due to intervening holidays) Defendant's Reply To Plaintiff's Response To Defendant's Motion For Summary Judgment Oral Argument - At the court's convenience.

February 18, 2005

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director s/Brian Cohen BRIAN COHEN Bell, Boyd, & Lloyd PLLC 1615 L. Street, N.W. Suite 1200 Washington, D.C. 20036 Tele: (202) 466-6300 FAX: (202) 835-4127 Attorney For Plaintiff s/Domenique Kirchner DOMENIQUE KIRCHNER 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) 307-0290 Fax: (202) 514-8624 Attorneys For Defendant November 12, 2004

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Case 1:98-cv-00868-FMA

Document 82

Filed 11/12/2004

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CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on this 12th day of November 2004, a copy of the foregoing "PARTIES' JOINT STATUS REPORT" was electronically filed. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. /s DOMENIQUE KIRCHNER