Almy et al v. United States Department of Defense et al

Filing 96

STATUS REPORT Joint by Michael D. Almy. (Woodmansee, Mark) (Filed on 12/17/2012)

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M. ANDREW WOODMANSEE (CA SBN 201780)
[e-mail]
STEPHANIE L. FONG (CA SBN 240836)
[e-mail]
KIMBERLY R. GOSLING (CA SBN 247803)
[e-mail]
JESSICA A. ROBERTS (CA SBN 265570)
[e-mail]
MORRISON & FOERSTER LLP
12531 High Bluff Drive
San Diego, California 92130-2040
Telephone: [phone]
Facsimile: 858.720.5125
JOHN M. GOODMAN (DC SBN 383147)
[e-mail]
SERVICEMEMBERS LEGAL DEFENSE NETWORK
P.O. Box 65301
Washington, DC 20035-5301
Telephone: [phone]
Facsimile: 202.797.1635
Attorneys for Plaintiff
MICHAEL D. ALMY

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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MICHAEL ALMY, JASON KNIGHT, and
ANTHONY LOVERDE,

JOINT STATUS REPORT

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Case No. cv 10-5627 (RS)

Plaintiffs,
v.
UNITED STATES DEPARTMENT OF
DEFENSE; ROBERT M. GATES, Secretary
of Defense; DEPARTMENT OF THE AIR
FORCE; MICHAEL B. DONLEY, Secretary,
Department of the Air Force; DEPARTMENT
OF THE NAVY; and RAY MABUS,
Secretary, Department of the Navy,
Defendants.

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JOINT STATUS REPORT
sd-606531

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On October 11, 2012, the parties filed a Stipulation to Stay Proceedings. (ECF No. 93.)

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On October 15, 2012, the Court granted the stipulation and ordered: “All proceedings in this case

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. . . shall be stayed pending the completion of the parties’ attempts to achieve a resolution outside

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this matter. The parties shall file a joint status report updating the Court on their settlement

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attempts on November 15, 2012, and every 30 days thereafter[.]” (ECF No. 94 at 2.) Pursuant to

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that order, the parties submit this Joint Status Report updating the Court on their settlement

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attempts.

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Status Update

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As stated in the parties’ last joint status report on November 15, 2012, the Government

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Defendants made a proposal to Plaintiff Michael Almy that would resolve this matter without

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further litigation. Mr. Almy considered the proposal and responded with a counter-proposal.

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Since then, the parties have continued these discussions and have exchanged further counter-

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proposals. The parties will continue this dialogue and their efforts to resolve this case without the

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Court’s involvement.

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JOINT STATUS REPORT
sd-606531

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DECLARATION PURSUANT TO CIVIL LOCAL RULE 5-1(i)(3).
I, M. ANDREW WOODMANSEE, hereby declare pursuant to Civil Local Rule 5-1(i)(3),

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that I have obtained the concurrence in the filing of this document from each of the other

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signatories listed below.

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I declare under penalty of perjury that the foregoing declaration is true and correct.

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Executed on December 17, 2012, in the City of San Diego, State of California.

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/s/ M. Andrew Woodmansee
M. ANDREW WOODMANSEE
12531 High Bluff Drive
San Diego, CA 92130
Phone: [phone]
Fax: [phone]
Email: [e-mail]

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Attorneys for Plaintiff

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/s/ Paul G. Freeborne
PAUL G. FREEBORNE
United States Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Avenue, NW, Room 6108
Washington, DC 20001
Phone: [phone]
Fax: [phone]
Email: paul.freeborne@.usdoj.gov

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Attorneys for Federal Defendants

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JOINT STATUS REPORT
sd-606531

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CERTIFICATE OF SERVICE
I hereby certify that all counsel of record, who are deemed to have consented to electronic

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service, are being served this 17th day of December, 2012, with a copy of this document via the

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Court’s CM/ECF system.

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/s/ M. Andrew Woodmansee
M. Andrew Woodmansee

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CERTIFICATE OF SERVICE
sd-606531