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

Case 1:06-cv-00418-NBF

Document 32

Filed 01/28/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS HOH RIVER TIMBER COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-418C (Judge Nancy B. Firestone)

DEFENDANT'S CONSENT MOTION TO STAY Defendant, the United States, respectfully requests that the Court stay this matter until March 31, 2008. Discovery is scheduled to close in this case on January 31, 2008. However, the parties have reached a tentative agreement to settle this matter. On January 22, 2008, undersigned counsel received plaintiff's written settlement offer and is in the process of requesting authority to finalize the settlement. Because approval (or denial) of authority to settle this matter has not yet been given, defendant respectfully requests that the Court stay this matter until March 31, 2008. Defendant has contacted plaintiff's counsel, who has indicated that plaintiff consents to this request.

Case 1:06-cv-00418-NBF

Document 32

Filed 01/28/2008

Page 2 of 3

Respectfully submitted,

JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director /s Bryant G. Snee BRYANT G. SNEE Deputy Director /s L. Misha Preheim L. MISHA PREHEIM Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L St., NW Washington, D.C. 20530 Tele: (202) 305-3087 Fax: (202) 305-1571

January 28, 2008

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Case 1:06-cv-00418-NBF

Document 32

Filed 01/28/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 28th day of January, 2008, a copy of the foregoing "Consent Motion To Stay" 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. The parties may access this filing through the Court's system.

s/ L. Misha Preheim

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