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

Case 1:01-cv-00351-JFM

Document 72

Filed 06/01/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS CLEARWATER CONSTRUCTORS, INC., ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 01-351C (Judge Merow)

JOINT STATUS REPORT In accordance with the Court's April 28, 2005 opinion and order, the parties file this joint status report to propose a schedule for further proceedings in this matter. The parties have agreed that, at this point, it is best to proceed with preparations for trial. Plaintiff would like to engage in mediation pursuant to the Court's ADR program, but the Government does not feel that mediation is appropriate at this time. The Government, nevertheless, is not averse to informal settlement negotiations between the parties as the case progresses towards trial. In any event, the parties have discussed a pretrial schedule and counsel for plaintiff has proposed the following schedule, which the Government does not oppose: Plaintiff's pretrial filings pursuant to RCFC Appendix A: January 5, 2007. Government's pretrial filings pursuant to RCFC Appendix A: February 2, 2007. Motions in limine: February 9, 2007. Pretrial Conference: Any time convenient to the Court after February 23, 2007. Trial: Any time convenient to the Court subsequent to the pretrial conference. The parties recognize that these proposed dates are somewhat distant, but they are dictated by the schedule of plaintiff's counsel, who already has multiple trials scheduled for the

Case 1:01-cv-00351-JFM

Document 72

Filed 06/01/2006

Page 2 of 2

Summer and Fall of this year and the availability of agency counsel, who is on extended active duty in the Air Force Reserves through early July. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/Todd M. Hughes TODD M. HUGHES Assistant Director

s/Jospeh A. Camardo, Jr. JOSEPH A. CAMARDO, JR. CAMARDO & ASSOCIATES 127 Genesee Street Auburn, NY 13021 Tel: (315) 252-3846 Fax: (315) 252-3508

s/J. Reid Prouty J. REID PROUTY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street, NW Washington, D.C. 20530 Tel: (202) 305-7586 Fax: (202) 514-7969 Attorneys for Defendant

Attorney for Plaintiff June 1, 2006

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