Case 1:01-cv-00046-FMA
Document 82
Filed 07/31/2005
Page 1 of 2
IN THE UNITED STATES COURT OF FEDERAL CLAIMS CUYAHOGA METROPOLITAN HOUSING AUTHORITY, Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) ) CONSOLIDATED CASE NOS. 01-46C, 01-251C AND 01-416C JUDGE ALLEGRA
JOINT STATUS REPORT
The parties submit this Joint Status Report in accordance with this Court's June 27, 2005 Order. Plaintiff has furnished Defendant calculations regarding damages in this case, and Defendant has acknowledged that its calculations are similar. The parties are in the process of assessing potential settlement scenarios. As this Court is aware, however, both Plaintiff and Defendant are governmental entities, and the decision-making process requires some time for assessment by all necessary divisions within the governmental entities. Additionally, since this Court entered its judgment, Judge Charles F. Lettow entered summary judgment on July 20, 2005, in the case of Statesman II Apts. v. United States, U.S. Court of Federal Claims Consolidated Case Nos. 04-805C and 04-806C. The parties are in the process of assessing the effect of Judge Lettow's decision on their potential settlement options in this case. As such, the parties respectfully request an additional 60 days until October 3, 2005, in which to finalize their options as to how this case should proceed. This request is made in good faith and not for purposes of delay.
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Case 1:01-cv-00046-FMA
Document 82
Filed 07/31/2005
Page 2 of 2
Respectfully submitted,
For the Plaintiff, /s/ Fred J. Livingstone FRED J. LIVINGSTONE TAFT, STETTINIUS & HOLLISTER LLP 3500 BP Tower 200 Public Square Cleveland, Ohio 44114-2302 (216) 241-2838 (216) 241-3707 (facsimile)
For the Defendant, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director s/Andrew P. Averbach ANDREW P. AVERBACH Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Attorney for Plaintiff Washington, D.C. 20530 Telephone: (202) 353-0527 Facsimile: (202) 305-2118
Of Counsel: Mark J. Valponi Majeed G. Makhlouf
Dated: July 31, 2005
K0222242.1
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