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

Case 1:05-cv-00915-MMS

Document 22

Filed 05/08/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CADDELL CONSTRUCTION, CO., INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-915C Judge Margaret M. Sweeney

DEFENDANT'S UNOPPOSED MOTION TO STAY THE CASE Defendant respectfully requests that the Court stay further proceedings in this action for 60 days, to and including July 7, 2007, in order to facilitate a potential settlement of this action. Defendant's counsel discussed this request with plaintiff's counsel, who indicated plaintiff does not oppose this motion. The parties and their attorneys conducted settlement negotiations in Savannah, Georgia on April 25, 2007. During these negotiations, a settlement offer was proposed, and defendant's counsel is preparing to forward this offer to appropriate Department of Justice officials with settlement authority. The 60 days are necessary to seek the necessary review of the offer within the Government, and, if the settlement is approved, to execute a settlement agreement with plaintiff. For these reasons, defendant respectfully requests that the Court grant this unopposed motion to stay this case for 60 days, to and including July 7, 2007.

Case 1:05-cv-00915-MMS

Document 22

Filed 05/08/2007

Page 2 of 2

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director s/Marla T. Conneely MARLA T. CONNEELY Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street Washington, D.C. 20530 tel: (202) 305-3689 fax: (202) 305-7643 May 8, 2007 Attorneys for Defendant

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