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

Case 1:06-cv-00351-ECH

Document 33

Filed 10/05/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS No. 06-351 T (Judge Emily C. Hewitt) ___________________________________ GISELE C. FISHER, Plaintiff, v.

THE UNITED STATES, Defendant ___________________________________ JOINT MOTION TO SUSPEND PROCEEDINGS ___________________________________ The parties respectfully request that the Court suspend proceedings to permit defendant to consider plaintiff's pending settlement offer. On October 4, 2007, plaintiff submitted to defendant an offer to settle all the unresolved issues in the above-captioned case. The Court of Federal Claims Section of the Tax Division of the United States Department of Justice intends shortly to recommend acceptance of this offer to the Tax Division's Office of Review, which has final settlement authority in this matter. Trial in this case is presently scheduled for October 16-18, 2007, in Seattle, Washington. Given this impending trial date, and that it is likely that a settlement of this case can be reached without further involvement of the Court, the parties believe that the interests of judicial economy will be served by granting the instant motion.

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Case 1:06-cv-00351-ECH

Document 33

Filed 10/05/2007

Page 2 of 2

This joint motion to suspend proceedings has been prepared in consultation with plaintiff, who has authorized the undersigned attorneys for defendant to represent to the Court that she joins in this motion. Respectfully submitted,

October 5, 2007

s/ Robert J. Higgins ROBERT J. HIGGINS Attorney of Record U.S. Department of Justice, Tax Division Court of Federal Claims Section Post Office Box 26, Ben Franklin Station Washington, D.C. 20044 TELEPHONE (202) 616-3423 FACSIMILE (202) 514-9440 RICHARD T. MORRISON Acting Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section G. ROBSON STEWART Reviewer, Court of Federal Claims Section JOSEPH B. SYVERSON Trial Attorney

October 5, 2007

s/ Steven I. Frahm Of Counsel

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