Case 1:00-cv-00512-FMA
Document 49
Filed 05/12/2008
Page 1 of 2
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
PETRO-HUNT, L.L.C.
Plaintiff,
v.
) ) ) ) ) )
)
Case No. 00-512L
Judge Allegr
UNTED STATES OF AMERICA
Defendant.
) ) ) )
JOINT MOTION TO LIFT THE STAY
Petro-Hwit, L.L.C. and the United States of America, by counsel, respectfully request
that this Cour lift the stay in this matter and issue an order setting the schedule for further action
as proposed by the parties below.
Plaintiff filed this lawsuit on August 24,2000. On October 31, 2000, plaintiff
fied a
Joint Motion to Stay these proceedings pending the outcome of
its quiet title action. Plaintiffs
Louisiana, Civil
quiet title action was fied in the U.S. District Court for the Western District of
Action No. CVOO-0303S. This cour entered an order staying these proceedings on November 2,
2000.
Plaintiffs application for a wrt of certiorari in the quiet title action was denied by the
U.S. Supreme Court on March 3,2008. As a result, the quiet title action is over. Plaintiff avers
that causes of action remain for consideration in this Court and intends to fie an amended
complaint setting forth its claims for relief.
Accordingly, the paries respectfuly request that the Court enter an order setting the
schedule for fuer action in this matter as follows:
Case 1:00-cv-00512-FMA
Document 49
Filed 05/12/2008
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(1) Plaintiff wil fie an amended complaint no later than 30 days after the order
liftng the stay is entered; i
(2) Defendant wil file its answer or other response no later than 60 days after
plaintiff fies its amended complaint; and
(3) No furher Joint Status Reports will be required afer the stay is lifted.
A proposed order is enclosed with this Motion.
Respectfully Submitted,
~f Co
. HWHI
Of
i ('" ~JÆ
( J ES D. GETTE nvironment and Natural Resources Division United States Department of Justice 601 D Street, N.W., P.O. Box 663 Washington, D.C. 20044-0663
Telephone: 202~305-146l
The White Law Firm 650 Poydras Street Suite 1605 New Orleans, Louisiana 70130
Telephone: 504-799-2585
Facsimile: 504-799-2588
Counsel: D. Joe Smith Edmund M. Amorosi
SMITH PACHTER MCWHORTER PLC
Facsimile: 202-514-8865
Attorney for Defendant
8000 Towers Crescent Drive, Suite 900 Vienna, Virginia 22182
Telephone: 703-847-6300 Facsimile: 703-847-63l2
Attorneys for Plaintif
Dated: May 12, 2008
¡Notwithstanding this joint motion to lift stay, Defendant reserves its right to raise all defenses to the amended complait proposed by Plaintiff, including but not limited to statute of limitations defenses.
Case 1:00-cv-00512-FMA
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Filed 05/12/2008
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IN THE UNITED STATES COURT OF FEDERAL CLAIMS Case No. 00-512L (Filed: _______) ____________________________________ ) ) ) Plaintiff, ) ) v. ) ) UNITED STATES OF AMERICA ) ) Defendant. ) ____________________________________) PETRO-HUNT, L.L.C. _____________ ORDER _____________ On May 12, 2008, the parties filed a join motion seeking to lift the stay in this case and to schedule further action in this matter. That motion is hereby GRANTED and this case is restored to the active docket. Accordingly, the parties are ordered to proceed as set forth below: (1) Plaintiff will file an amended complaint no later than 30 days after the order lifting the Stay is entered; (2) Defendant will file its answer or other response no later than 60 days after plaintiff files its amended complaint; and (3) No further Joint Status Reports will be required. IT IS SO ORDERED.
Case No. 00-512L Judge Allegra
______________________ Francis M. Allegra Judge