PEARSE-HOCKER v. USA

Filing 33

JOINT STATUS REPORT, filed by ANNE PEARSE-HOCKER, USA. (Brown, Walter)

IN THE UNITED STATES COURT OF FEDERAL CLAIMS
ANNE PEARSE-HOCKER,

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Plaintiff,
v.
THE UNITED STATES,
Defendant.

No. 10-269 C
Judge Edward J. Damich

JOINT STATUS REPORT
In accordance with the Court’s April 18, 2011, Order, plaintiff Anne Pearse-Hocker and
defendant, the United States, hereby submit this Joint Status Report, which addresses the parties’
specific progress and plans towards settlement. In its Order, the Court granted the parties a 45day continued stay of proceedings in this case based on progress made in settlement discussions
between the parties. During this stay, the parties have worked to complete a Settlement
Agreement and a Stipulation for Entry of Judgment (Stipulation). As explained below, the
parties are close to completing these documents and executing a settlement, and thus, are
concurrently filing a Motion for Continuation of a Stay. This motion requests a continued stay
of eight additional days, to and including June 10, 2011.
Since the Court’s April 18, 2011, Order, the parties have moved closer to completing
settlement. On May 24, 2011, plaintiff submitted a formal written offer, enclosing a draft
Settlement Agreement and Stipulation for Entry of Judgment. The defendant’s attorney of
record and the Smithsonian Institution have recently recommended approval of this offer.
Accordingly, defendant is requesting an eight-day to provide sufficient time to obtain the
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necessary authorizations to execute the settlement documents and to file the Stipulation with the
Court.
Respectfully submitted,
THOMPSON HINE LLP
Dated: June 2, 2011

By:s/Eric N. Heyer by Walter W. Brown
Eric N. Heyer
1920 N Street, N.W., Suite 800
Washington, D.C. 20036
Telephone: [phone]
Fax: [phone]
[e-mail]
Counsel for Plaintiff Anne Pearse-Hocker

TONY WEST
Assistant Attorney General
JOHN FARGO
Director
Dated: June 2, 2011

s/Walter W. Brown
Walter W. Brown
Attorney
Commercial Litigation Branch
Civil Division
Department of Justice
Washington, D. C. 20530
Telephone: [phone]
Facsimile: [phone]
Attorneys for the United States

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