Fannie Mae-No Politics (FNMA)

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS
)
FAIRHOLME FUNDS, INC., et al., )
)
Plaintiffs, )
)
v. ) No. 13-465C
) (Judge Sweeney)
THE UNITED STATES, )
)
Defendant. )
)

JOINT MOTION FOR LEAVE TO FILE JOINT STATUS REPORT OUT OF TIME
The parties respectfully request that the Court grant this joint motion for leave to file the
joint status report due on May 27, 2016 one day out of time. On May 20, 2016, the Court issued
an order construing Defendant’s notice of apparent violation of the protective order effective in
this case as a motion and denying it (Doc. 326). The Court also ordered the parties to file, no
later than May 27, 2016, a joint status report advising whether the Court’s Order should remain
unsealed. Due primarily to the press of other deadlines, the parties inadvertently neglected to file
the joint status report on time. Accordingly, we respectfully request that the Court permit the
parties to file the joint status report, which is attached, on May 31, 2016.

Date: May 31, 2016
BENJAMIN C. MIZER
Principal Deputy Assistant Attorney General
s/ Robert E. Kirschman, Jr.
ROBERT E. KIRSCHMAN, JR.
Director
s/ Kenneth M. Dintzer
KENNETH M. DINTZER
Deputy Director
Commercial Litigation Branch
U.S. Department of Justice
P.O. Box 480 Ben Franklin Station
Washington, D.C. 20044
[phone]
[phone] fax
[e-mail]
Attorneys for Defendant
Respectfully submitted,
s/ Charles J. Cooper
Charles J. Cooper
Counsel of Record for Plaintiffs
COOPER & KIRK, PLLC
1523 New Hampshire Avenue, N.W.
Washington, D.C. 20036
[phone]
[phone] (fax)
[e-mail]
Of counsel:
Vincent J. Colatriano
David H. Thompson
Peter A. Patterson
Brian W. Barnes
COOPER & KIRK, PLLC
1523 New Hampshire Avenue, N.W.
Washington, D.C. 20036
[phone]
[phone] (fax)
CERTIFICATE OF SERVICE


I hereby certify that a true and accurate copy of the foregoing was served upon all
counsel of record on this 31st day of May, 2016, via the Court’s Electronic Case Filing system.
s/ Kenneth M. Dintzer
KENNETH M. DINTZER