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

Case 1:08-cv-00113-CCM

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Filed 05/27/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ALCATEC, LLC, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 08-113C (Judge C. Miller)

DEFENDANT'S MOTION UPON BEHALF OF THE PARTIES TO SUSPEND ALL PROCEEDINGS FOR 90 DAYS Defendant, upon behalf of the parties, respectfully requests that this Court issue an order to suspend all proceedings in this matter for 90 days, to and including August 26, 2008. Defendant's response to the complaint is now due on May 28, 2008, and the Court previously has granted defendant an enlargement of time of 30 days within which to respond to Alcatec, LLC's ("ALCATEC") complaint. ALCATEC's counsel has reviewed this motion and authorizes Government counsel to state that ALCATEC joins in this motion. Because of other related matters that potentially would affect any discovery in this action, both parties believe that the interests of justice and the most efficient resolution of this matter can be best achieved by suspending all proceedings in this matter for 90 days.

Case 1:08-cv-00113-CCM

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Filed 05/27/2008

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For the foregoing reasons, the parties respectfully request that this Court grant this motion and enter an order suspending all proceedings in this matter for 90 days, to and including August 26, 2008, and direct the defendant to file a status report regarding further proceedings on or before August 26, 2008.1 Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director REGINALD T. BLADES, JR. Assistant Director OF COUNSEL: John A. Thompson Senior General Attorney General Law Division Office of the General Counsel DHS/Federal Emergency Management Agency /s/ John. S. Groat JOHN S. GROAT Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 616-8260 Fax: (202) 514-7965 [email protected] Attorneys for Defendant

May 27, 2008

Should the Court deny this motion, the Government respectfully requests that the Court provide for the Government to file its response to ALCATEC's complaint within 14 days of the Court's order.

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Case 1:08-cv-00113-CCM

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Filed 05/27/2008

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CERTIFICATE OF FILING I hereby certify that on May 27, 2008, a copy of the foregoing DEFENDANT'S MOTION ON BEHALF OF THE PARTIES TO SUSPEND ALL PROCEEDINGS FOR 90 DAYS, was filed electronically. I understand that notice of this filing 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/John S. Groat

Case 1:08-cv-00113-CCM

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Filed 05/27/2008

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