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

Case 1:06-cv-00436-MCW

Document 38

Filed 05/23/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ULYSSES, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-436C (Judge Williams)

DEFENDANT'S CONSENT MOTION TO CONTINUE STAY AND TO RESCHEDULE STATUS CONFERENCE Defendant, the United States, respectfully requests this Court to continue the stay of this case, and to reschedule the status conference currently scheduled for May 28, 2008. This is defendant's first such request, and plaintiff consents to this request. On February 26, 2008, this Court issued an order, granting plaintiff's motion to stay this case. See Feb. 26, 2008 Order Staying Proceedings. In that order, this Court also set a status conference for May 28, 2008 "to discuss the status of the ongoing criminal investigation." Id. The parties have consulted, however, and are unaware of any new developments in this case that would warrant lifting the stay currently in place. Moreover, undersigned counsel of record was hospitalized last week for two days, and has an important follow-up doctor's appointment on May 28, 2008 that is likely to conflict with the status conference scheduled for that same date. Accordingly, the parties respectfully request that the status conference be rescheduled for sometime in August 2008. Alternatively, we request that the parties be permitted to file joint status reports every 90 days to notify the Court regarding the status of the criminal investigation or events that may warrant lifting the stay of this case.

Case 1:06-cv-00436-MCW

Document 38

Filed 05/23/2008

Page 2 of 2

Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Deborah A. Bynum DEBORAH A. BYNUM Assistant Director s/ Matthew H. Solomson MATTHEW H. SOLOMSON Trial Attorney Commercial Litigation Branch Civil Division, U.S. Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 305-3274 May 23, 2008 Counsel for Defendant

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