Case 1:05-cv-00707-LJB
Document 16
Filed 07/22/2008
Page 1 of 3
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
STEVEN R. CHARVES, Plaintiff, v. UNITED STATES OF AMERICA, Defendant.
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Case No. 05-707C (Judge Lynn J. Bush)
PLAINTIFF'S UNOPPOSED MOTION FOR A STAY OF PROCEEDINGS Plaintiff in the above-captioned civil action moves the Court for a stay of proceedings pending this Court's decisions in Boyer v. United States, Case No. 00-641C; Wolfen v. United States, Case No. 03-2665C; and Antonsen v. United States, Case No. 04-163C. In support of this motion plaintiff submits the following: On June 19, 2008, in the above-three captioned cases, defendant filed a motion for judgment on the pleadings. On July 21, 2008, plaintiffs filed their Opposition to Defendant's Motion for Judgment on the Pleadings, Dismissing the Claims Remaining to be Adjudicated. Plaintiff recognizes that the issues presented in the instant case are in all material respects the same as those presented in the foregoing cases. Plaintiff believes that it would be unnecessarily duplicative for the Court and the parties to continue to file almost identical briefs in the instant case and propose that the Court stay further proceedings in this case until the Court has rendered decisions in the three above-captioned cases. Counsel for plaintiff in the instant case has discussed this motion with counsel for defendant. Counsel for defendant, Shalom Brilliant, has authorized the undersigned to represent to the Court that defendant does not oppose the granting of this motion.
Case 1:05-cv-00707-LJB
Document 16
Filed 07/22/2008
Page 2 of 3
Respectfully submitted,
OF COUNSEL: Linda Lipsett
s/Jules Bernstein Jules Bernstein (Counsel of Record) Bernstein & Lipsett, P.C. 1920 L Street, N.W., Suite 303 Washington, D.C. 20036 (202) 296-1798 (202) 296-7220 facsimile Counsel of Record
s/Edgar James James & Hoffman, P.C. 1101 17th Street, N.W., Suite 510 Washington, D.C. 20036 (202) 496-0500 (202) 496-0555 facsimile Attorneys for Plaintiff Dated: July 22, 2008
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Case 1:05-cv-00707-LJB
Document 16
Filed 07/22/2008
Page 3 of 3
CERTIFICATE OF FILING
I hereby certify under penalty of perjury that on this 22nd day of July 2008, a copy of the foregoing "PLAINTIFF'S UNOPPOSED MOTION FOR A STAY OF PROCEEDINGS" was 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.