Almy et al v. United States Department of Defense et al
Filing
97
STATUS REPORT Joint by Michael D. Almy. (Gosling, Kimberly) (Filed on 1/14/2013)
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M. ANDREW WOODMANSEE (CA SBN 201780)
MAWoodmansee@mofo.com
STEPHANIE L. FONG (CA SBN 240836)
SFong@mofo.com
KIMBERLY R. GOSLING (CA SBN 247803)
KGosling@mofo.com
JESSICA A. ROBERTS (CA SBN 265570)
JRoberts@mofo.com
MORRISON & FOERSTER LLP
12531 High Bluff Drive
San Diego, California 92130-2040
Telephone: 858.720.5100
Facsimile: 858.720.5125
JOHN M. GOODMAN (DC SBN 383147)
jgoodman@sldn.org
SERVICEMEMBERS LEGAL DEFENSE NETWORK
P.O. Box 65301
Washington, DC 20035-5301
Telephone: 202.328.3244
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
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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’ joint status reports on November 15, 2012, and December 17,
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2012, the Government Defendants made a proposal to Plaintiff Michael Almy that would resolve
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this matter without further litigation. Mr. Almy considered the proposal and responded with a
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counter-proposal. Since then, the parties have continued these discussions and have exchanged
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further counter-proposals. The parties are currently in the process of finalizing a resolution of
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this matter.
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JOINT STATUS REPORT
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DECLARATION PURSUANT TO CIVIL LOCAL RULE 5-1(i)(3).
I, KIMBERLY R. GOSLING, hereby declare pursuant to Civil Local Rule 5-1(i)(3), that I
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have obtained the concurrence in the filing of this document from each of the other signatories
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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 January 14, 2013, in the City of San Diego, State of California.
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/s/ Kimberly R. Gosling
KIMBERLY R. GOSLING
12531 High Bluff Drive
San Diego, CA 92130
Phone: (858) 720-5100
Fax: (858) 720-5125
Email: kgosling@mofo.com
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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: (202) 353-0543
Fax: (202) 616-8460
Email: paul.freeborne@.usdoj.gov
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Attorneys for Federal Defendants
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JOINT STATUS REPORT
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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 14th day of January, 2013, with a copy of this document via the
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Court’s CM/ECF system.
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/s/ Kimberly R. Gosling
Kimberly R. Gosling
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CERTIFICATE OF SERVICE
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