Franklin-Mason v. Johnson

District of Columbia, dcd-1:2003-cv-00945

Joint STATUS REPORT by RAY MABUS.

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ROXANN J. FRANKLIN-MASON, Plaintiff, v. Civil Action No. 03-0945 (JEB) THOMAS MODLY, Acting Secretary of the Navy, Defendant. JOINT STATUS REPORT Pursuant to the Court's Minute Order dated October 15, 2019, the parties, by and through undersigned counsel, hereby submit the following status report to apprise the Court of the status of settlement discussions regarding Defendant's Bill of Costs in this action. On October 23, 2019, Plaintiff submitted a settlement offer to Defendant. In turn, Defendant submitted a counteroffer to Plaintiff on October 25, 2019. Plaintiff requires additional time to review Defendant's counteroffer. Also, the parties believe that an additional amount of time would be beneficial for the parties to engage in further discussions to settle the issue of costs without the need for a judicial decision. Accordingly, the parties respectfully request that they be permitted to file an additional joint status report by November 8, 2019, to further apprise the Court of the status of settlement discussions. A proposed order is attached. Respectfully submitted, ROBINSON BROG LEINWAND GREENE GENOVESE & GLUCK, P.C. By: /s/ Lisa Alexis Jones Lisa Alexis Jones, Esq. 875 Third Avenue 9th Floor New York, N.Y. 10022 (212) 603-6344 laj@robinsonbrog.com Counsel for Plaintiff JESSIE K. LIU, D.C. Bar # 472845 United States Attorney DANIEL VAN HORN, D.C. Bar # 924092 Chief, Civil Division /s/ Christopher C. Hair CHRISTOPHER C. HAIR, PA Bar # 306656 Assistant United States Attorney United States Attorney's Office 555 4th Street, N.W. Washington, D.C. 20530 (202) 252-2541 christopher.hair@usdoj.gov Counsel for Defendant 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ROXANN J. FRANKLIN-MASON, Plaintiff, v. Civil Action No. 03-0945 (JEB) THOMAS MODLY, Acting Secretary of the Navy, Defendant. [PROPOSED] ORDER Upon consideration of the parties' Joint Status Report, it is hereby ORDERED that the parties will submit an additional status report on or before November 8, 2019. ___________________ _____________________ Date Hon. James E. Boasberg United States District Judge