Free Status Report - District Court of Federal Claims - federal

Case 1:94-cv-00518-EGB

Document 155

Filed 06/01/2004

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS MONARCH ASSURANCE, P.L.C., and THOMAS PATRICK DENTON TAYLOR, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) )

No. 94-518C (Judge Bruggink)

DEFENDANT'S STATUS REPORT Defendant respectfully submits the following status report. By order dated May 4, 2004, the Court directed the Government to file a brief by June 1, 2004, that addresses the safeguards the United States believes should be included in the letters rogatory that the Court will send to the appropriate court in the United Kingdom, pursuant to the plaintiff's request to conduct depositions in the United Kingdom. However, after careful

deliberation, the United States has concluded that it will not be necessary to ask the Court to include any safeguards in the letters rogatory. Accordingly, the United States will not be

filing a brief to address these matters. Government counsel has communicated this decision to plaintiff's counsel. Counsel have conferred with regard to these

developments, and propose that they file a stipulation with regard to the letters rogatory that plaintiff will ask the Court to transmit to an appropriate court in the United Kingdom.

Case 1:94-cv-00518-EGB

Document 155

Filed 06/01/2004

Page 2 of 3

Plaintiff's counsel will provide Government counsel with a draft, and the parties request that the Court allow them 30 days from today to file a stipulation with the Court. In light of these developments, the parties propose that, by July 1, 2004, they file a joint stipulation with regard to the conduct of these depositions. Respectfully submitted, PETER D. KEISLER Assistant Attorney General /s David M. Cohen DAVID M. COHEN Director /s Thomas D. Dinackus THOMAS D. DINACKUS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, DC 20530 Tele: (202) 307-6289 Fax: (202) 514-7969 Attorneys for Defendant OF COUNSEL: Robert Morean Office of General Counsel Central Intelligence Agency June 1, 2004

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Case 1:94-cv-00518-EGB

Document 155

Filed 06/01/2004

Page 3 of 3

NOTICE OF FILING I hereby certify that on June 1, 2004, a copy of the foregoing "DEFENDANT'S STATUS REPORT" 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. I hereby further certify that on June 1, 2004, I caused to be served by United States mail (first class, postage prepaid) copies of the foregoing "DEFENDANT'S STATUS REPORT" addressed as follows: Raphael S. Moore, Esq. 413 F Street Davis, CA 95616

/s Thomas D. Dinackus