Free Status Report - District Court of Federal Claims - federal

Case 1:94-cv-00518-EGB

Document 149

Filed 02/09/2004

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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, upon behalf of both parties, pursuant to the Court's order. Plaintiff's counsel has reviewed this status report and has authorized defendant to file it upon behalf of both parties. Counsel met to discuss the conduct of discovery on March 10, 2003. In particular, counsel discussed the procedures that could

be used to safeguard classified information that might be revealed during the course of discovery. Counsel subsequently

continued these discussions via telephone, and Government counsel sent plaintiff's counsel a letter, dated May 22, 2003, that presented the Government's current views with regard to the procedures that should be used to safeguard whatever classified information might be revealed during the course of discovery. Plaintiffs and plaintiffs' British counsel are reviewing the Government's May 22, 2003 letter. Plaintiff's counsel has yet to

hear from plaintiff and his British counsel, but expects to

Case 1:94-cv-00518-EGB

Document 149

Filed 02/09/2004

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receive their written comments in the near future. counsel will then confer with Government counsel.

Plaintiff's

In light of these activities, the parties propose that, by March 11, 2004, they file a joint stipulation with regard to the conduct of discovery, or a status report if they have been unable to reach agreement with regard to a joint stipulation. 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 OF COUNSEL: Robert Morean Office of General Counsel Central Intelligence Agency February 9, 2004 Attorneys for Defendant

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Case 1:94-cv-00518-EGB

Document 149

Filed 02/09/2004

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NOTICE OF FILING I hereby certify that on February 9, 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 February 9, 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