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

Case 1:01-cv-00495-EGB

Document 276

Filed 02/23/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

) ) ) Plaintiffs ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) ) ) ) ) ____________________________________ )

KENT CHRISTOFFERSON, et al.,

Case No. 01-495C Judge Eric G. Bruggink

JOINT STATUS REPORT Counsel for plaintiffs hereby submit a joint status report on behalf of the parties. Counsel for defendant has read and concurs with this Status Report. On February 20, 2007, plaintiffs' counsel twice unsuccessfully attempted to email defense counsel a database containing data for 1,995 plaintiffs who completed and returned Claim Forms . It is possible that the database file was too large for the receiving mailbox. Plaintiff's counsel sent a CD containing the database file to defense counsel by Federal Express on February 21, 2007. Plaintiff's counsel is in the process of completing the database and plans to send defense counsel the data for the remainder of plaintiffs who completed and returned Claim Forms by approximately March 13, 2007. On February 13, 2007, plaintiffs' counsel filed a Motion for Leave to Amend the First

Case 1:01-cv-00495-EGB

Document 276

Filed 02/23/2007

Page 2 of 2

Amended Complaint (FAC). This motion seeks leave to amend the FAC to include a cause of action for unpaid straight time work, that is, hours of work up to or less than 40 hours per week. In processing the Claim Forms, plaintiffs' counsel has found that a majority of the non-Concord, CA plaintiffs have claims for unpaid straight time work in addition to their claims for unpaid overtime work. Counsel for defendant will request leave of the Court to extend the date defendant's opposition to plaintiffs' motion. Plaintiff's counsel does not oppose the request and will likewise seek leave for an extension of the date the reply is due. Respectfully submitted,

February 23, 2007

s/ JACK W. LEE MINAMI TAMAKI LLP 360 Post Street, 8th Floor San Francisco, CA 94108 Phone: 415 788-9000 Fax: 415 398-3887 Attorneys for Plaintiffs

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