Free Motion to Stay - District Court of Federal Claims - federal

Case 1:03-cv-00101-ECH

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Filed 02/17/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS WHITE SANDS CONSTRUCTION, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 03-101C (Judge Hewitt)

DEFENDANT'S UNOPPOSED MOTION TO CONTINUE STAY AND FILE STIPULATION FOR DISMISSAL ON MARCH 12, 2004 Defendant respectfully requests that this action remain stayed until March 12, 2004, and that the Court direct the parties to file the stipulation for dismissal on March 12, 2004. Counsel for defendant has discussed this motion with plaintiff's counsel. Plaintiff does not oppose this motion.

Plaintiff is scheduled to receive payment in settlement of this matter from the Defense Finance and Accounting Service on February 28, 2004. After plaintiff receives payment, the parties

will file a stipulation for dismissal. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Bryant G. Snee BRYANT G. SNEE Assistant Director

Case 1:03-cv-00101-ECH

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Filed 02/17/2004

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s/Michael N. O'Connell MICHAEL N. O'CONNELL Trial Attorney U.S. Department of Justice Civil Division Commercial Litigation Branch 1100 L St., N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel.: (202) 307-0282 Attorneys for Defendant

OF COUNSEL: MAJOR LARRY ANDERSON AFLSA/JACN 1501 Wilson Blvd. Room 606 Arlington, VA 22209-2403

February 17, 2004

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Case 1:03-cv-00101-ECH

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Filed 02/17/2004

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CERTIFICATE OF FILING I hereby certify that on February 17, 2004, a copy of the foregoing defendants' motion to continue stay and file stipulation for dismissal on March 12, 2004 was filed electronically. I understand that a copy of the Answer will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. s/Michael N. O'Connell MICHAEL N. O'CONNELL

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