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

Case 1:07-cv-00274-ECH

Document 21

Filed 05/14/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

WOLVERINE WORLD WIDE, INC., Plaintiff, v. UNITED STATES OF AMERICA, Defendant.

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No. 07-274C (Hewitt, E.)

CONSENT MOTION FOR A STAY OF PROCEEDINGS Plaintiff, Wolverine World Wide, Inc. ("Wolverine"), by its undersigned attorneys, with the consent and agreement of defendant, the United States of America, hereby moves the Court to stay proceedings in this action to allow implementation of a settlement that the parties have reached this date. Such a stay will dispense with the need for the Court to decide Wolverine's pending Motion for Temporary Restraining Order and/or Preliminary Injunction, which the Court was to do by May 15, 2007, and it likewise will dispense with the need for defendant to file the Administrative Record on May 15, 2007, as it currently is required to do. The parties anticipate that the settlement terms will be implemented by the afternoon of May 17, 2007, following which plaintiff will file with the Court a stipulation for dismissal of this action. Pursuant to discussions of counsel for the parties with the Court, held this date, it is agreed that if the referenced stipulation for dismissal is not filed by 12:00 PM, noon, on May 18, 2007, the stay is to be lifted and the current schedule under which the parties are operating will be moved forward by one week.

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Case 1:07-cv-00274-ECH

Document 21

Filed 05/14/2007

Page 2 of 2

FILED UNDER SEAL Counsel of record for plaintiff is authorized to state that counsel of record for defendant has reviewed this motion and agrees with it. WHEREFORE, Wolverine World Wide, Inc. respectfully requests that the Court grant this consent motion for a stay of proceedings. Respectfully submitted, OF COUNSEL: David T. Ralston, Jr. Steven C. Lambert FOLEY & LARDNER LLP 3000 K Street, N.W., Suite 500 Washington, D.C. 20007-5143 Telephone 202.672.5300 Facsimile 202.672.5399 Dated May 14, 2007 s/ Philip A. Nacke Philip A. Nacke FOLEY & LARDNER LLP 3000 K Street, N.W., Suite 500 Washington, D.C. 20007-5143 Telephone 202.295.4086 Facsimile 202.672.5399 Counsel of Record for Plaintiff Wolverine World Wide, Inc.

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