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

Case 1:07-cv-00719-MBH

Document 20

Filed 06/03/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

MRAG AMERICAS, INC., Plaintiff, v. UNITED STATES, Defendant.

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No. 07-719C (Judge Horn)

JOINT MOTION TO STAY PROCEEDINGS Defendant, United States, and plaintiff, MRAG Americas, Inc., respectfully request that the Court stay the proceedings in this case for forty days, until July 13, 2008. Counsel for the parties are currently engaged in settlement discussions. 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 July 13, 2008. The parties propose to file a joint status report on or before July 13, 2008, regarding the status of settlement activities.

Case 1:07-cv-00719-MBH

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Filed 06/03/2008

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Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Martin F. Hockey, Jr. MARTIN F. HOCKEY, JR. Assistant Director

s/ David S. Black DAVID S. BLACK Holland & Knight LLP 1600 Tysons Boulevard, Suite 700 McLean, VA 22102-4867 tel: (703) 720-8600 fax: (703) 720-8610

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 June 3, 2008

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Case 1:07-cv-00719-MBH

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Filed 06/03/2008

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CERTIFICATE OF FILING

I hereby certify that on the 3rd day of June, 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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