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

Case 1:06-cv-00231-EJD

Document 16

Filed 06/26/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) ____________________________________) EDWARD GRINNELL,

06-231 C (Chief Judge Damich)

PLAINTIFF'S SECOND MOTION TO STAY Plaintiff in the above captioned matter, by and through undersigned counsel, hereby moves this Court, pursuant to Rule 6 of the Rules of the United States Court of Federal Claims ("RCFC") to stay proceedings in this matter. The Parties are engaged in settlement discussions regarding all claims before this Court and a further stay of the proceedings before this Court for a period of sixty (60) days will allow the Parties to continue settlement discussions. WHEREFORE, Appellant prays this Court grant its Motion to Stay, order that Appellant shall file an Amended Complaint within 60 days of the Court's Order and grant all such other and further relief as this Court deems just. Respectfully submitted, Dated: June 23, 2006 s/ Sean D. Magenis SEAN D. MAGENIS Kelly & Associates, LLC 96 High Street Belfast, Maine 04915 207-338-2702 207-338-0328 (fax) Attorney for Plaintiff

Case 1:06-cv-00231-EJD

Document 16

Filed 06/26/2006

Page 2 of 2

CERTIFICATE OF SERVICE I, Sean D. Magenis, Esq., hereby certify that on this 22d day of June, 2006, I electronically filed Plaintiff's Motion to Stay using the CM/ECF system which will send notification of such filing(s) to the following: PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director BRIAN M. SIMKIN Assistant Director SEAN B. McNAMARA Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, NW Washington, D.C. 20530 (202) 305-7573 (202) 514-8624 (fax) Attorneys for defendant s/ Sean D. Magenis Sean D. Magenis