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

Case 1:07-cv-00218-NBF

Document 33

Filed 04/16/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ***************************** GREAT LAKES DREDGE & DOCK COMPANY, LLC as the Successor in Interest of GREAT LAKES DREDGE & DOCK COMPANY, for the Use and Benefit of WILKINSON & JENKINS CONSTRUCTION CO., INC., Plaintiff, No. 07-00218 C v. Judge Firestone UNITED STATES, Defendant. ***************************** JOINT STATUS REPORT REGARDING PARTIES' PROPOSALS FOR COMPLETING EXPERT DISCOVERY Pursuant to the Court's March 5, 2008 Order, Plaintiff, Great Lakes Dredge & Dock Company, LLC as the Successor in Interest of Great Lakes Dredge & Dock Company, for the Use and Benefit of Wilkinson & Jenkins Construction Co, Inc. ("Plaintiff") and Defendant, United States ("Defendant") file this Joint Status Report and state: I. Defendant's Expert Discovery As required by the Court's Order, the Defendant served the Expert Report of its Expert, Wiley R. Wright, III, on April 3, 2008. II. Plaintiff's Expert Discovery Plaintiff's and Defendant's Rule 26(a)(1) Initial Disclosures identified potential trial witnesses in this matter before Defendant determined it wished to retain an additional expert witness. Plaintiff does not need to retain any further expert witnesses to address the facts of the case or to rebut the Defendant's new expert, as the Plaintiff believes the Defendant's expert witness is essentially restating the allegations and analysis contained in the Defendant's original

Case 1:07-cv-00218-NBF

Document 33

Filed 04/16/2008

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audit report. That audit report was previously addressed by Plaintiff prior to filing of the lawsuit with the assistance of Plaintiff's listed witnesses. Accordingly, Plaintiff does not require any additional witnesses. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/Donald E. Kinner DONALD E. KINNER Assistant Director s/Joseph W. Lawrence, II JOSEPH W. LAWRENCE, II Vezina, Lawrence & Piscitelli, P.A. The Museum Building 300 SW First Avenue, Suite 150 Fort Lauderdale, Florida 33301 Tel: Fax: (954) 728-1270 (954) 728-1270 s/Armando A. Rodriguez-Feo ARMANDO A. RODRIGUEZ-FEO Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L St., NW Washington, D.C. 20530 Tel: Fax: Attorney for Plaintiff April 16 2008 __ (202) 307-3390 (202) 514-8624

Attorneys for Defendant

Case 1:07-cv-00218-NBF

Document 33

Filed 04/16/2008

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CERTIFICATE OF FILING

I hereby certify that on this 16th day of April, 2008, a copy of the foregoing "JOINT STATUS REPORT REGARDING PARTIES' PROPOSALS FOR COMPLETING EXPERT DISCOVERY," 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/Armando Rodriguez-Feo