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

Case 1:98-cv-00726-EJD

Document 152

Filed 01/04/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GRASS VALLEY TERRACE, A CALIFORNIA LIMITED PARTNERSHIP, et al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 98-726C, and consolidated cases (Chief Judge Damich)

JOINT STATUS REPORT Pursuant to the Court's Order of December 6, 2004, the parties respectfully submit the following information. (1) The parties propose the following discovery schedule relating to the claims of

Quincy Investment Group and Northway Investment Group: January 12, 2005: Service of initial disclosures pursuant to RCFC 26(a)(1) relating to the claims of Quincy Investment Group and Northway Investment Group. Completion of fact discovery relating to the claims of Quincy Investment Group and Northway Investment Group. Service of plaintiffs' expert report relating to the claims of Quincy Investment Group and Northway Investment Group. Service of defendant's expert report relating to the claims of Quincy Investment Group and Northway Investment Group. Completion of expert discovery relating to the claims of Quincy Investment Group and Northway Investment Group.

March 3, 2005:

March 17, 2005:

April 5, 2005:

April 21, 2005:

Case 1:98-cv-00726-EJD

Document 152

Filed 01/04/2005

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(2)

Defendant hereby advises the Court that it intends to file a motion to dismiss

based upon the statute of limitations issues discussed during the November 29, 2004 status conference for certain properties owned by NRCB Limited Partnership and The Highlands Limited Partnership, and any other similarly situated properties in this litigation. The parties propose that defendant's motion be filed on or before March 11, 2005. (3) Pursuant to the Court's order , the parties have completed and attached a draft

pretrial order that the parties propose to be entered in this case. Respectfully submitted, PETER D. KEISLER Assistant Attorney General s/ David M. Cohen DAVID M. COHEN Director s/ Jeff H. Eckland JEFF H. ECKLAND Eckland & Blando LLP 700 Lumber Exchange 10 South Fifth Street Minneapolis, MN 55402 Tele: (612) 305-4444 Fax: (612) 305-4439 s/ Shalom Brilliant SHALOM BRILLIANT Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit Room 8012 Washington, D.C. 20530 Tele: (202) 305-7561 Fax: (202) 305-7643 Attorneys for Defendant

Attorney for Plaintiffs Dated: January 4, 2005 Filed Electronically with the consent of the Attorney for Plaintiffs 2