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

Case 1:07-cv-00056-EJD

Document 28

Filed 01/09/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

) ) Plaintiff, ) ) v. ) ) UNITED STATES, ) ) ) Defendant . ) ____________________________________)

BASS MANAGEMENT, INC.,

Case No. 07-056C (Chief Judge Damich)

JOINT MOTION FOR STAY OF PROCEEDINGS The parties respectfully request that the Court stay discovery in this matter in order to allow the parties to continue with settlement discussions. The parties believe that a stay would be in the interest of the parties and of judicial economy so that the parties may focus on settlement negotiations. Presently fact discovery is scheduled to conclude on February 5, 2008. The parties hope to resolve this dispute without the assistance of the Court and without the need for further discovery within 90 days, to and including April 8, 2008. The parties have exchanged settlement proposals and are hopeful that resolution of this matter will occur soon. Accordingly, the parties propose that the parties file a joint status report every 45 days to inform the Court of the status of settlement discussions. For the foregoing reasons, the parties respectfully request that the Court stay all proceedings in this matter until April 8, 2008.

Case 1:07-cv-00056-EJD

Document 28

Filed 01/09/2008

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Respectfully submitted, JEFFREY S. BUCHOLZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director /s Kirk T. Manhardt KIRK T. MANHARDT Assistant Director

s/Frank W. Trapp Frank W. Trapp, MB #8261 Phelps Dunbar LLP 111 East Capitol Street, Suite 600 Jackson, Mississippi 39201-2122 P.O. Box 23066 Jackson, Mississippi 39225-3066 Telephone: (601) 352-2300 Facsimile: (601) 360-9777

/s David M. Hibey DAVID M. HIBEY 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) 307-0163 Fax: (202) 514-8624

Attorneys for Plaintiff

Attorneys for Defendant

January 9, 2008

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Case 1:07-cv-00056-EJD

Document 28

Filed 01/09/2008

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CERTIFICATE OF FILING I hereby certify that on this 9th day of January, 2008, a copy of the foregoing "Joint Motion For Stay of Proceedings" 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/ David M. Hibey

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