Free Proposed Pretrial Order - District Court of Federal Claims - federal

Case 1:94-cv-00522-MCW

Document 297

Filed 11/28/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS FIRST ANNAPOLIS BANCORP, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 94-522C (Judge Williams)

PROPOSED JOINT PRE-TRIAL SCHEDULE Pursuant to the Court's request during the November 16, 2006 status conference, plaintiff, First Annapolis Bancorp, Inc., and defendant, the United States, respectfully submit the following proposed pre-trial schedule: Dec. 27, 2006: Meeting of counsel pursuant to paragraph 13 of Appendix A with exchange of initial exhibit and witness lists; Jan. 15, 2007: Bancorp's memorandum of contentions of law and fact due pursuant to paragraph 14, along with final witness and exhibit lists pursuant to paragraphs 15 and 16, respectively; Feb. 9, 2007: United States' memorandum of contentions of law and fact due pursuant to paragraph 14, along with final witness and exhibit lists pursuant to paragraphs 15 and 16, respectively; Feb. 16, 2007: Motions In Limine and objections to exhibits due; Feb. 23, 2007: Responses to Motions In Limine due; Feb. 28, 2007: Final Pre-Trial Conference ­ Argument on Motions In Limine; Mar. 12-23, 2007: Trial on Bancorp's damages claims as presently scheduled.

Case 1:94-cv-00522-MCW

Document 297

Filed 11/28/2006

Page 2 of 4

Pursuant to the Court's instruction during the November 16, 2006 status conference, defendant contacted its expert witnesses to ascertain their availability for trial in March, 2007. Although one of defendant's experts is available the week of March 19, the week that defendant intends to present its defensive case, our other expert, Prof. Alan Shapiro, is unavailable that week. Accordingly, defendant requests a delay of one week to the week of March 26 to present its defensive case. Plaintiff opposes such a change in the schedule and thus, the parties seek a telephonic status conference to address the trial schedule. Respectfully submitted, COOTER, MANGOLD, TOMPERT & KARAS, L.L.P. s/Dale A. Cooter Dale A. Cooter 5301 Wisconsin Avenue, NW Suite 500 Washington, DC 20015 Tel: (202) 537-0700 FAX: (202) 364-3664 OF COUNSEL: JAMES E. TOMPERT Attorney for Plaintiff First Annapolis Bancorp, Inc. November 28, 2006 STUART E. SCHIFFER Deputy Assistant Attorney General JEANNE E. DAVIDSON Deputy Director s/William F. Ryan WILLIAM F. RYAN Assistant Director s/Richard B. Evans RICHARD B. EVANS Trial Attorney Commercial Litigation Branch, Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Telephone: (202) 353-7760 Facsimile: (202) 305-7643

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Case 1:94-cv-00522-MCW

Document 297

Filed 11/28/2006

Page 3 of 4

OF COUNSEL: TIMOTHY ABRAHAM MELINDA HART MARK PITTMAN DELISA SANCHEZ Trial Attorneys Attorneys for Defendant November 28, 2006

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Case 1:94-cv-00522-MCW

Document 297

Filed 11/28/2006

Page 4 of 4

CERTIFICATE OF FILING I hereby certify that on November 28, 2006, a copy of the foregoing "PROPOSED JOINT PRETRIAL SCHEDULE" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/Richard B. Evans

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