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

Case 1:07-cv-00778-LAS

Document 11

Filed 04/17/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TODD R. FORBES, Plaintiff, v. UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-778C (Judge Smith)

JOINT MOTION TO STAY PROCEEDINGS Defendant, United States, and plaintiff, Todd R. Forbes, respectfully request that the Court stay the proceedings in this case for sixty days, until June 16, 2008. Counsel for the parties are currently engaged in settlement discussions. Counsel of record for the United States has received a written offer of settlement from the plaintiff, which will be presented to the authorized representative of the Attorney General for consideration and decision. The proposed stay will allow counsel for both parties sufficient opportunity to discuss this matter with respective clients and to work out the terms of a settlement, should that occur. We respectfully request, therefore, that the Court grant our joint motion to stay proceedings until June 16, 2008. The parties propose to file a joint status report on June 16, 2008, regarding the status of settlement activities.

Case 1:07-cv-00778-LAS

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Filed 04/17/2008

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Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director s/ Deborah A. Bynum DEBORAH A. BYNUM Assistant Director

s/ John B. Wells JOHN B. WELLS Attorney at Law Post Office Box 5235 Slidell, Louisiana 70469-5235 tel: (985) 641-1855 fax: (985) 649-1536

s/ Joseph A. Pixley JOSEPH A. PIXLEY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 307-0843 Fax: (202) 307-0972 Attorneys for Defendant

Attorney for Plaintiff April 17, 2008

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Case 1:07-cv-00778-LAS

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Filed 04/17/2008

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CERTIFICATE OF FILING

I hereby certify that on the 17th day of April, 2008, a copy of the foregoing "JOINT MOTION TO STAY" 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/Joseph A. Pixley

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