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

Case 1:06-cv-00933-LB

Document 5

Filed 03/01/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS No. 06-933 T (Judge Lawrence J. Block)

E. HAFFNER FOURNIER and JOANNE FOURNIER et. al., Plaintiffs, v. THE UNITED STATES, Defendant.

JOINT MOTION FOR SUSPENSION OF PROCEEDINGS

The parties, through their attorneys, respectfully request that proceedings be suspended in the above-captioned case. This case is an AMCOR case that presents issues of fact and law in common with Robert J. Isler and Susan L. Isler v. United States, Fed. Cl. No. 01-344 T, Jeffrey T. Scuteri v. United States, Fed. Cl. No. 01-358 T, Ronald C. Prati and Mary G. Prati v. United States, Fed. Cl. No. 02-60 T, Kenneth C. Keener v. United States, Fed. Cl. No. 03-2028 T, William P. Smith, Jr. and Anne D. Smith v. United States, Fed. Cl. No. 04-907 T, and John F. and Pamela F. Hinck v. United States, Fed. Cl. No. 03-865 T. Accordingly, the parties request that proceedings be suspended pending a final decision in Isler, Scuteri, Prati, Keener, and Smith, and final appellate action in Hinck. Plaintiffs' attorney has authorized defendant's attorney to sign this motion on his behalf.*

Defendant's answer in this matter was due Tuesday, February 27, 2007. Pursuant to the parties' standard practice, the parties intended to file this standard joint AMCOR suspension motion with the Court on or before that date, in lieu of defendant filing an answer. The parties -1-

*

Case 1:06-cv-00933-LB

Document 5

Filed 03/01/2007

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Respectfully submitted,

3/01/2007 Date

s/Thomas E. Redding by s/Bart D. Jeffress THOMAS E. REDDING Redding & Associates, P.C. 2914 W.T.C. Jester Houston, Texas 77018 (713) 965-9244 (713) 621-5227 (fax) Attorney for Plaintiffs

3/01/2007 Date

s/Bart D. Jeffress BART D. JEFFRESS Attorney of Record U.S. Department of Justice Tax Division Court of Federal Claims Section Post Office Box 26 Ben Franklin Post Office Washington, D.C. 20044 (202) 307-6496 (202) 514-9440 (fax) EILEEN J. O'CONNOR Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section STEVEN I. FRAHM Assistant Chief, Court of Federal Claims Section

3/01/2007 Date

s/Steven I. Frahm Of Counsel Attorneys for Defendant

missed that date, in large part because defendant's attorney of record was in Canada from February 19, 2007 to February 27, 2007, to attend to an important and unexpected family matter, and did not return to the office until today (March 1, 2007). -2-