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

Case 1:01-cv-00151-ECH

Document 63

Filed 01/09/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS RYCO CONSTRUCTION CO. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 01-151C (Judge Hewitt)

JOINT STATUS REPORT Pursuant to the Court's August 11, 2003 order, the parties submit the following joint status report.1 Since the granting of the parties' joint motion to stay proceedings on August 11, 2003, the parties have held numerous settlement discussions and exchanged several settlement proposals. The parties now have agreed upon an amount that can

be recommended to the appropriate Department of Justice settlement authority. Additional time is necessary to complete a

draft of the memorandum requesting authority from the appropriate Department of Justice official to settle the case. If the offer

is accepted by the appropriate Department of Justice official, additional time then will be necessary to prepare a stipulation for entry of judgment for filing with the Court. Pursuant to the Court's August 11, 2003 order, the parties will file a status report with the Court on or before February

The Court's order requires the filing of a joint status report every 30 days. Our previous status report was filed on December 12, 2003. This status report is due to be filed by January 12, 2004.

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Case 1:01-cv-00151-ECH

Document 63

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11, 2004, discussing the parties' progress towards possible settlement of this case. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Todd M. Hughes TODD M. HUGHES Assistant Director s/ David B. Stinson DAVID B. STINSON Trial Attorney Commercial Litigation Branch 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 Date: January 9, 2004

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Case 1:01-cv-00151-ECH

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s/ Paul M. Mahoney PAUL M. MAHONEY Jones, Mahoney, Brayton & Soll 150 West First Street, Suite 280 Claremont, California 91711 Tele: (909) 399-9977 Fax: (909) 399-5959 Date: January 6, 2004

Attorney for Plaintiff

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Case 1:01-cv-00151-ECH

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CERTIFICATE OF SERVICE I certify under penalty of perjury that on this 9th day of JANUARY 2004, I caused to be placed in United States mail (firstclass mail, postage prepaid) copies of "JOINT STATUS REPORT" addressed as follows:

PAUL M. MAHONEY Jones, Mahoney, Brayton & Soll 150 West First Street, Suite 280 Claremont, California 91711 s/ David B. Stinson