Free Status Report - District Court of Federal Claims - federal

Case 1:03-cv-01798-EJD

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Filed 03/11/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ___________________________________ ) AMERICAN RENOVATION AND ) CONSTRUCTION COMPANY, ) ) Case No. 03-1798C Plaintiff, ) (Chief Judge Damich) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) ___________________________________) JOINT STATUS REPORT COMES NOW the Plaintiff, American Renovation & Construction Company ("ARC" or "Plaintiff") and the Defendant, the United States, by counsel, and pursuant to the Court's Order dated February 28, 2005, submit this Joint Status Report, stating as follows: 1. 2. 3. Plaintiff, ARC, filed the Complaint in this case on July 28, 2003. The United States filed its Answer on November 25, 2003. As represented in prior Joint Status Reports ("JSR"), the parties have

been attempting to negotiate an amicable resolution of all their disputes relating to the construction project at issue in this case. Since the submission of the last JSR, on February 24, 2005, the parties have made significant progress towards reaching a global settlement of all their disputes relating to the underlying Project. Specifically: a. Following the production by Plaintiff of additional documents and clarifications regarding costs incurred on the Project, the parties have exchanged informal proposals concerning how the various disputes can be resolved.

Case 1:03-cv-01798-EJD

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b. positions. c.

The parties met on March 10, 2005 to discuss their respective

The parties require approximately one more week to review and

respond to the latest proposal. 4. Based upon discussions to-date, the parties are hopeful that they will be

able to reach an amicable settlement of their disputes. 5. On November 19, 2004, Classical Financial Services, LLC filed a motion

to intervene in this lawsuit and the motion was fully briefed as of January 7, 2005. At this time, the Court's ruling on the motion is pending. Respectfully submitted, s/ Harish C. Mirchandani HARISH C. MIRCHANDANI Watt, Tieder, Hoffar & Fitzgerald, L.L.P 8405 Greensboro Drive, Suite 100 McLean, VA 22102 Tel. (703) 749-1000 Fax. (703) 893-8039 Attorney for Plaintiff DATED: March 11, 2005 Of Counsel: ROBERT G. WATT Watt, Tieder, Hoffar & Fitzgerald, L.L.P 8405 Greensboro Drive, Suite 100 McLean, VA 22102 Tel. (703) 749-1000 Fax. (703) 893-8039 s/Michael N. O'Connell MICHAEL N. O'CONNELL Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, DC 20530 Tel. (202) 305-3634 Fax. (202) 514-8624 Attorneys for Defendant DATED: March 11, 2005 PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Robert E. Kirschman, Jr. ROBERT E. KIRSCHMAN, JR. Assistant Director

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Case 1:03-cv-01798-EJD

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Filed 03/11/2005

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CERTIFICATE OF FILING I hereby certify that on March 11, 2005, a copy of the foregoing Joint Status Report was filed electronically. I understand that a copy of the Joint Status Report 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/ Michael N. O'Connell

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