Free Motion for Miscellaneous Relief - District Court of Federal Claims - federal

Case 1:04-cv-00557-GWM

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Filed 11/17/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ELLIS C. BLAND, et al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) No. 04-557C ) ) (Judge George W. Miller) ) ) )

DEFENDANT'S MOTION TO FILE INDIVIDUAL STATUS REPORT IN LIEU OF JOINT STATUS REPORT Defendant, the United States, respectfully requests that the Court grant leave for the Government to file the individual status report, incorporated below, in lieu of a joint status report. Undersigned counsel has been unable to reach plaintiffs' counsel to discuss this status report. Rather than seek an

enlargement of time to file a joint status report, we believe that it would be more efficient and helpful to the Court, as well as to plaintiffs' counsel, to file an individual status report, which will serve the same purpose as a joint status report. Therefore, we respectfully request that the Court grant this motion for leave to file the individual status report incorporated below. DEFENDANT'S STATUS REPORT Defendant, the United States, respectfully submits this joint status report, apprising the Court of the status of the ADR

Case 1:04-cv-00557-GWM

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proceedings in the above-referenced matter and the following related proceedings: Busigo v. United States, Fed. Cl. No. 05422; Case v. United States, Fed. Cl. No. 05-687C; Dupuis v. United States, Fed. Cl. No. 06-82C; Fleury v. United States, Fed. Cl. No. 06-156; Nokell v. United States, Fed. Cl. No. 06-335; and Smith v. United States, Fed. Cl. No. 06-592. The initial ADR session was conducted before Judge Hewitt on November 15, 2006. The session lasted the entire day and the Progress towards

parties engaged in substantive negotiations. settlement was made.

An additional session has been scheduled

for December 13, 2006 to continue discussions. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

Case 1:04-cv-00557-GWM

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s/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/ Richard P. Schroeder RICHARD P. SCHROEDER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7562 Facsimile: (202) 305-3291 email: [email protected] Attorneys for Defendant November 17, 2006

Case 1:04-cv-00557-GWM

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this day of November 17, 2006, "DEFENDANT'S MOTION TO FILE INDIVIDUAL STATUS REPORT IN LIEU OF JOINT 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.

s/Richard P. Schroeder