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

Case 1:05-cv-00575-TCW

Document 50

Filed 03/15/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) ____________________________________)

PHILLIP J. LAVEZZO d/b/a DKO TECHNOLOGIES,

No. 05-575C (Judge Wheeler)

JOINT MOTION TO STAY Pursuant to Rule 7(b) of the Rules of the United States Court of Federal Claims, the parties jointly request that further proceedings in this case be stayed for 31 days to allow settlement negotiations. Pursuant to this Court's December 7, 2006 Order and Opinion, the Federal Labor Relations Authority ("FLRA") appointed Ms. Janis Anderson of the General Services Administration ("GSA") as contracting officer to review Mr. Lavezzo's claim. On March 14, 2007, Mr. Lavezzo and his counsel met with the GSA contracting officer, and other GSA staff to explore the possibility of settlement. Counsel for the United States participated by telephone. As a result of this meeting, the parties believe that settlement may be possible, without further involvement of the Court. Therefore, the parties request that the current obligation to produce a contracting officer's final decision on or before March 16, 2007, be stayed for 31 days to allow the counsel for the Government to obtain settlement authority, and to allow the parties to negotiate the terms of a mutually agreeable settlement agreement. The parties propose that if they are unable to file a joint stipulation of dismissal on or before April 16, 2007, that they file a joint status report detailing the status of the settlement negotiations.

Case 1:05-cv-00575-TCW

Document 50

Filed 03/15/2007

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director

s/ David M. Knasel DAVID M. KNASEL DOMINION BUSINESS LAW PLC 8280 Greensboro Drive Suite 601 McLean, Virginia 22102 Telephone: (703) 918-9301 Facsimile: (703) 738-7268

s/ David D'Alessandris DAVID D'ALESSANDRIS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit, 8th Floor Washington, D.C. 20530 Telephone: (202) 307-0139 Facsimile: (202) 514-8624 Attorneys for Defendant March 15, 2007

Attorney for Plaintiff March 15, 2007

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Case 1:05-cv-00575-TCW

Document 50

Filed 03/15/2007

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CERTIFICATE OF SERVICE I hereby certify that on the 15th day of March, 2007, a true and correct copy of the foregoing was filed electronically through the U.S. Court of Federal Claims Case Management Electronic Case Files system. I understand that notice of this filing will be sent to all

parties/counsel of record by the Court's electronic filing system and that they may access this filing through that system.

s/David D'Alessandris

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