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

Case 1:06-cv-00940-EJD

Document 10

Filed 11/09/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) ____________________________________) COEUR D'ALENE TRIBE,

Case No. 06-cv-00940l Judge Edward J. Damich

PARTIES' JOINT MOTION FOR LIFTING OF TEMPORARY STAY OF LITIGATION FOR LIMITED PURPOSE, AND FOR APPROVAL AND ENTRY OF PARTIES' JOINT STIPULATION AND [PROPOSED] ORDER REGARDING COMMUNICATION, REPORT, OR WORK PRODUCT PURSUANT TO CERTAIN COOPERATIVE AGREEMENT AND ANY AMENDMENT THERETO Pursuant to Rule 7(b) of the Rules of the Court of Federal Claims ("RCFC"), the parties respectfully make this joint motion for the lifting of the current temporary stay of litigation for a limited purpose and for the approval and entry of the parties' Joint Stipulation and [Proposed Order] Regarding Communication, Report, or Work Product Pursuant to a Certain Cooperative Agreement and Any Amendment Thereto, as an Order of the Court. The grounds in support of this joint motion are set forth in the memorandum appended hereto. Respectfully submitted this 9th day of November, 2007, RONALD J. TENPAS Acting Assistant Attorney General /s/ John P. Racin, by /s/ E. Kenneth Stegeby, pursuant to written authorization on November 8, 2007 JOHN P. RACIN 1721 Lamont Street, N.W. Washington, D.C. 20010 Tel: (202) 265-2516 Fax: (202) 483-7895

/s/ E. Kenneth Stegeby E. KENNETH STEGEBY United States Department of Justice Environment and Natural Resources Division P.O. Box 663 Washington, D.C. 20044-0663 Tel: (202) 616-4119

Case 1:06-cv-00940-EJD

Document 10

Filed 11/09/2007

Page 2 of 2

Fax: (202) 353-2021 Attorney of Record for Plaintiff Attorney of Record for Defendant OF COUNSEL: ANTHONY P. HOANG United States Department of Justice Environment and Natural Resources Division P.O. Box 663 Washington, D.C. 20044-0663 Tel: (202) 305-0241 Fax: (202) 353-2021 MICHAEL BIANCO Office of the Solicitor United States Department of the Interior Washington, D.C. 20240 TERESA E. DAWSON Office of the Chief Counsel Financial Management Service United States Department of the Treasury Washington, D.C. 20227

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