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

Case 1:05-cv-00906-RHH

Document 14

Filed 02/08/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS MARIAN K. HANSSON, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) No. 05-906C ) ) Judge Robert H. Hodges, Jr. ) )

JOINT MOTION TO STAY PROCEEDINGS Pursuant to the Rule 7 of the Rules of the United States Court of Federal Claims ("RCFC"), the parties request that the Court stay the proceedings in this case for 47 days, to and including March 27, 2006. A supplement to the parties joint preliminary status report is currently due on February 9, 2006. If the motion to stay is granted, our report would be due on March 27, 2006. The parties recently commenced settlement negotiations and request this stay for the purpose of completing those negotiations. The parties anticipate that this matter will be resolved. This Court possesses the inherent power to order the conduct of litigation as necessary to achieve the just, speedy, and inexpensive resolution of every action. Landis v. North Am. Co., 299 U.S. 248, 254 (1936); RCFC 1. Under these circumstances, the benefits of judicial economy and the conservation of resources for the parties and the Court outweigh whatever delay might result from the suspension of proceedings. The interests of efficiency, economy, and justice all militate in favor of staying discovery in this matter. For the foregoing reasons, we respectfully request that the Court grant this motion for a stay of proceedings.

Case 1:05-cv-00906-RHH

Document 14

Filed 02/08/2006

Page 2 of 2

Respectfully submitted, s/ Charles W. Day, Jr. CHARLES W. DAY, JR. Gebhardt & Associates, LLP 1101 17th Street, N.W., Suite 807 Washington, DC 20036-4716 Tel: (202) 496-0400 Fax: (202) 496-0404 PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director

s/ David R. Feniger DAVID R. FENIGER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 307-3390 Fax: (202) 305-2118 Attorneys for Defendant February 8, 2006