Free Status Report - District Court of Federal Claims - federal

Case 1:98-cv-00405-ECH

Document 173

Filed 01/12/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

CROMAN CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant.

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No. 98-405C (Judge Hewitt)

PLAINTIFF'S STATUS REPORT AND REQUEST FOR A STATUS CONFERENCE As the Court is aware, for some time now the parties have jointly reported approximately every 60 days that they are interested in settling this matter, that a detailed settlement offer was prepared by plaintiff and that defendant is evaluating that offer. For example, in its status report of October 14, 2005, plaintiff reported on its having sent defendant an outline for settlement on July 14, 2005. Likewise, by status report of February 6, 2006, plaintiff reported that defendant had proffered a series of questions with regard to damages and settlement to which plaintiff had completed most answers (the subsequent status report dated April 7, 2006 indicated that plaintiff had furnished answers to all questions as well as material in support thereof). Thereafter, as referenced in defendant's status reports of August 8, 2006 and October 10, 2006, plaintiff provided a restated and re-supported offer of settlement on July 8, 2006 (revised on July 31, 2006).

While plaintiff does not doubt that defendant and its counsel are sincere in their statements that defendant is interested in achieving a negotiated settlement of this matter, the fact 1

Case 1:98-cv-00405-ECH

Document 173

Filed 01/12/2007

Page 2 of 2

remains that defendant, for a variety of reasons, has, over the last six months, at best devoted minimal effort to analyzing and responding to plaintiff's detailed settlement proposal. Such being the case, plaintiff believes that some judicial overview of the settlement process is needed to help the parties achieve a settlement of this case.

To this end, plaintiff respectfully requests a status conference, preferably in either open court or in chambers to discuss means by which the Court can provide assistance to the parties.

Respectfully submitted,

s/Alan I. Saltman SALTMAN & STEVENS, P.C. 1801 K Street, N.W. Suite M-110 Washington, D.C. 20006 (202) 452-2140 Counsel for Plaintiff Of Counsel: Richard W. Goeken SALTMAN & STEVENS, P.C. 1801 K Street, N.W. Suite M-110 Washington, D.C. 20006 (202) 452-2140 Dated: January 12, 2007

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