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

Case 1:06-cv-00427-CFL

Document 25

Filed 04/21/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BERNARD d'ABRERA and HILL HOUSE PUBLISHERS PTY LTD., Plaintiffs, v. THE UNITED STATES, Defendant. BERNARD d'ABRERA and HILL HOUSE PUBLISHERS PTY LTD., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 06-427 C Judge Charles F. Lettow

No. 07-365 C Judge Charles F. Lettow

DEFENDANT'S UNOPPOSED MOTION TO STAY PROCEEDINGS Defendant the United States ("the government") moves to stay all proceedings in these consolidated cases for a period of sixty (60) days from the grant of this Motion, so that the government may consider an offer of settlement from Plaintiffs. This is the government's first motion for this purpose. On April 21, 2008, counsel for Plaintiffs advised counsel for the government that Plaintiffs do not oppose the requested sixty (60) day stay of all proceedings. Statement in Support of Motion On April 18, 2008, Plaintiffs submitted a formal offer of settlement that will dispose of these consolidated cases. Defendant's counsel is prepared to recommend that this offer be accepted. However, the time requested is needed to enable the appropriate officials to consider this offer and

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Case 1:06-cv-00427-CFL

Document 25

Filed 04/21/2008

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authorize its acceptance. To avoid further expenditure of time and resources, the government moves that all proceedings in this action be stayed for sixty days to permit appropriate consideration of Plaintiffs' offer of settlement. Conclusion For the above reasons, Defendant respectfully requests that this unopposed Motion be granted.

Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JOHN J. FARGO Director

OF COUNSEL: LAURYN GUTTENPLAN Smithsonian Institution

April 21, 2008

s/ Scott Bolden SCOTT BOLDEN Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Washington, DC 20530 Telephone: (202) 307-0262 Facsimile: (202) 307-0345

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