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

Case 1:07-cv-00134-SGB

Document 26

Filed 08/26/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ALIAMANU CONSERVATION PARTNERS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-134C (Judge Braden)

JOINT MOTION FOR STAY Pursuant to Rule 7 of the Rules of the United States Court of Federal Claims, the parties respectfully request a stay of all proceedings in this case for 90 days, to and including November 25, 2008. The parties have negotiated a proposed settlement and require additional time to submit the proposal to the Chief Counsel of the Army Corps of Engineers for his recommendation and then forward the recommended proposal to the authorized representative of the United States Attorney General for consideration. See 28 C.F.R. § 0.161. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director s/Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director

Case 1:07-cv-00134-SGB

Document 26

Filed 08/26/2008

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s/Timothy H. Power TIMOTHY H. POWER Law Offices of Timothy H. Power 19229 Sonoma Highway Suite 246 Sonoma, CA 95476 Tel: (707) 343-1550 Fax: (707) 343-1552

s/Armando A. Rodriguez-Feo ARMANDO A. RODRIGUEZ-FEO Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L St., NW Washington, D.C. 20530 Tel: (202) 307-3390 Fax: (202) 514-8624 Attorneys for Defendant

Attorney for Plaintiff August 26, 2008

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Case 1:07-cv-00134-SGB

Document 26

Filed 08/26/2008

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CERTIFICATE OF FILING I hereby certify that on this 26th day of August, 2008, a copy of foregoing "JOINT MOTION FOR 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/ Armando Rodriguez-Feo