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

Case 1:06-cv-00397-LJB

Document 18

Filed 01/11/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS AMY ASSOCIATES, GANTT W. MILLER, et al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

Nos. 06-397C 06-616C

PLAINTIFFS' MOTION UPON BEHALF OF THE PARTIES TO CONTINUE ADR SESSION Plaintiffs, upon behalf of both parties, by counsel, hereby request that the ADR session presently scheduled for January 18 and 19, 2007 be continued. Counsel for defendant has read this motion, and consents to its terms. Plaintiffs represent to the Court that both parties have, thus far, conducted informal settlement discussions. However, due the complexity of the issues in this case, Plaintiffs to date have been unable to provide the Government with its initial proof of damages, in order to facilitate a timely response from Defendant. At this time, Plaintiffs intend to submit the initial information and demand by January 19, 2007. The Defendant intends to respond to said demand by February 19, 2007. Both parties recognize the importance of conducting productive ADR sessions. Due to this anticipated exchange of information and the availability of counsel, the parties suggest an initial ADR session no earlier than March 19, 2007, but as soon as possible after that date.

Case 1:06-cv-00397-LJB

Document 18

Filed 01/11/2007

Page 2 of 2

Respectfully submitted, /s/Christopher P. Stroech Christopher P. Stroech, Esq. Arnold, Cesare & Bailey, PLLC P.O. Box 69, 117 E. German Street Shepherdstown, WV 25443 304.876.1575 304.876.9186 [email protected] Attorney for Plaintiffs

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