HAGERMAN et al v. THE SOCIALIST PEOPLE'S LIBYAN ARAB JAMAHIRIYA

Filing 103

STATUS REPORT by SOCIALIST PEOPLE'S LIBYAN ARAB JAMAHIRIYA, LIBYAN EXTERNAL SECURITY ORGANIZATION, LIBYAN ARAB AIRLINES. (Attachments: # 1 Exhibit Exhibits A-D)(Curran, Christopher)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
_______________________________________
)
ETHEL HURST, et al.,
)
)
Plaintiffs,
)
)
v.
)
)
SOCIALIST PEOPLE’S LIBYAN ARAB
)
JAMAHIRIYA, et al.,
)
)
Defendants.
)
_______________________________________)

Civil Action No. 1:02-cv-02147 (HHK)

STATUS REPORT
In light of recent legislative and diplomatic developments, the Libyan Defendants (i.e.,
the Libyan State Defendants and the Libyan Individual Defendants) submit this status report
setting forth the status of this matter and any future proceedings that may be necessary.
On July 31, 2008 Congress passed and on August 4, 2008 the President signed the Libyan
Claims Resolution Act, Pub. L. No. 110-301 (2008) (Exhibit A). On August 14, 2008 the United
States and Libya executed a Claims Settlement Agreement (Exhibit B). On October 31, 2008,
Secretary of State Condoleezza Rice delivered to the House and Senate Committees on Foreign
Relations and on the Judiciary the Certification under Section 5(a)(2) of the Act. See Press
Release and Certification (Exhibit C). In addition, on October 31, 2008, President Bush signed
an Executive Order regarding settlement of claims against Libya. See Executive Order (Exhibit
D).
In view of the requisite dismissal of this and similar actions involving Libya upon the
Secretary of State’s Certification under the Act, the Libyan State Defendants have contacted

Plaintiffs requesting a stipulation of dismissal under Rule 41(a)(1)(A)(ii) of the Federal Rules of
Civil Procedure. If the parties are unable to enter such a stipulation promptly, the Libyan State
Defendants will file a motion to dismiss.

Dated: November 7, 2008

Respectfully submitted,

/s/ Christopher M. Curran
Christopher M. Curran (D.C. Bar No. 408561)
Francis A. Vasquez, Jr. (D.C. Bar No. 442161)
Nicole E. Erb (D.C. Bar No. 466620)
701 Thirteenth Street, N.W.
Washington, D.C. 20005
Telephone: [phone]
Facsimile: [phone]
Counsel for the Socialist People’s Libyan Arab
Jamahiriya, Libyan External Security Organization,
and Libyan Arab Airlines

BAACH ROBINSON & LEWIS PLLC
/s/ Eric L. Lewis_____________________
Eric L. Lewis (D.C. Bar No. 344643)
Alan Croft (D.C. Bar No. 442388)
1201 F Street, N.W. Suite 500
Washington, D.C. 20004-1225
Telephone: [phone]
Facsimile: [phone]
Counsel for Defendant Abdel Basset Ali AlMegrahi

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