NATIONAL VETERANS LEGAL SERVICES PROGRAM et al v. UNITED STATES OF AMERICA

Filing 91

Joint STATUS REPORT Proposing a Schedule to Govern Further Proceedings by ALLIANCE FOR JUSTICE, NATIONAL CONSUMER LAW CENTER, NATIONAL VETERANS LEGAL SERVICES PROGRAM. (Narwold, William)

Case 1:16-cv-00745-ESH Document 91 Filed 04/16/18 Page 1 of 4

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
NATIONAL VETERANS LEGAL
SERVICES PROGRAM, NATIONAL
CONSUMER LAW CENTER, and
ALLIANCE FOR JUSTICE, for themselves
and all others similarly situated,

)
)
)
)
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Plaintiffs,
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v.
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UNITED STATES OF AMERICA,
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Defendant.
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)
__________________________________________)

Civil Action No. 16-745 (ESH)

JOINT STATUS REPORT PROPOSING A SCHEDULE
TO GOVERN FURTHER PROCEEDINGS
As the Court ordered, (ECF 88 at 1), the parties have conferred regarding a
plan for the remainder of this case, and believe that further proceedings are necessary
to determine the amount of an illegal exaction, if any. They jointly request that the
Court approve the following proposed schedule:
1.

The parties shall complete fact discovery by September 30, 2018.

2.

The parties shall complete expert discovery by March 1, 2019.

3.

All motions for summary judgment, if any, shall be filed on April 15, 2019.

The parties also request that the Court hold a status conference following the
close of expert discovery on March 1, 2019, and before the due date for summaryjudgment motions on April 15, 2019 to determine the most efficient plan for further
proceedings at that point, including whether a brief bench trial may be appropriate.

Case 1:16-cv-00745-ESH Document 91 Filed 04/16/18 Page 2 of 4

April 16, 2018

Respectfully submitted,
By:

/s/ William H. Narwold
William H. Narwold (D.C. Bar No. 502352)
MOTLEY RICE LLC
One Corporate Center
20 Church Street, 17th Floor
Hartford, CT 06103
Phone: [phone]
Fax: [phone]
[e-mail]
Deepak Gupta (D.C. Bar No. 495451)
Jonathan E. Taylor (D.C. Bar No. 1015713)
GUPTA WESSLER PLLC
1900 L Street, NW
Washington, D.C. 20036
Phone: [phone]
Fax: [phone]
[e-mail], [e-mail]
Elizabeth Smith (D.C. Bar No. 994263)
MOTLEY RICE LLC
401 9th Street, NW, Suite 1001
Washington, D.C. 20004
Phone: [phone]
Fax: [phone]
Meghan S.B. Oliver (D.C. Bar No. 493416)
MOTLEY RICE LLC
28 Bridgeside Blvd.
Mount Pleasant, SC 29464
Phone: [phone]
Fax: [phone]
For Plaintiffs.

Case 1:16-cv-00745-ESH Document 91 Filed 04/16/18 Page 3 of 4

JESSIE K. LIU (D.C. Bar No. 472845)
United States Attorney
DANIEL F. VAN HORN (D.C. Bar No. 924092)
Chief, Civil Division
By:

/s/ Brian Field
BRIAN FIELD (D.C. Bar No. 985577)
W. MARK NEBEKER (D.C. Bar No. 396739)
Assistant United States Attorneys
555 4th Street, N.W.
Washington, D.C. 20530
[phone]
[e-mail]; [e-mail]
For Defendant

Case 1:16-cv-00745-ESH Document 91 Filed 04/16/18 Page 4 of 4

CERTIFICATE OF SERVICE
I hereby certify that on April 16, 2018, I authorized the electronic filing of this
Joint Status Report Proposing a Schedule to Govern Further Proceedings through this
Court’s CM/ECF system. I understand that notice of this filing will be sent to all parties
by operation of the Court’s electronic filing system.

/s/ William H. Narwold
William H. Narwold