Free Motion for Miscellaneous Relief - District Court of Federal Claims - federal

Case 1:05-cv-01236-LMB

Document 39

Filed 03/30/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS EVA P. WHITE, as Administratrix ) of the Estate of CHRISTINE H. ) ROBERTS, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 05-1236C (Judge Baskir)

JOINT MOTION FOR ENTRY OF JUDGMENT In accordance with the Court's order of March 26, 2007, plaintiff, Eva P. White, and defendant, the United States, respectfully submit this motion for entry of judgment. Following the Court's ruling upon the parties' cross motions for judgment upon the administrative record, 74 Fed. Cl. 769 (2006), and there being no further factual determinations to be made by the Bureau of Justice Assistance, the parties agree that this matter is ripe for final judgment. Accordingly, and without defendant consenting to, or waiving any rights to pursue further review of, the Court's decision in this case, the parties respectfully request that the Court enter judgment awarding plaintiff $250,000 in accordance with Pub. L. No. 107-56, § 613(a) and (b) (Oct. 26, 2001) and 42 U.S.C.A. § 3796(i), there being no adjustment due pursuant to 42 U.S.C.A. § 3796(h).

Case 1:05-cv-01236-LMB

Document 39

Filed 03/30/2007

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director s/William M. Beasley (rmp, with permission) WILLIAM M. BEASLEY Phelps Dunbar, LLP Seventh Floor One Mississippi Plaza 201 South Spring Street Post Office Box 1220 Tupelo, MS 38802-1220 Tel: (662) 842-7907 Fax: (662) 842-3873 s/Allison Kidd-Miller ALLISON KIDD-MILLER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St. Washington, D.C. 20530 Tel: (202) 307-3050 Fax: (202) 307-0972 Of Counsel: RAFAEL MADAN General Counsel JASON P. COOLEY Attorney Advisor Office of the General Counsel Office of Justice Programs Department of Justice 810 7th Street, N.W. Washington, D.C. 20531 Attorney for Plaintiff March 30, 2007 -2Attorneys for Defendant

Case 1:05-cv-01236-LMB

Document 39

Filed 03/30/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 30th day of March, 2007, a copy of the foregoing "Joint Motion For Entry Of Judgment" and "Order" were filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. s/Allison Kidd-Miller