Case 1:04-cv-00711-CCM
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IN THE UNITED STATES COURT OF FEDERAL CLAIMS DAFNA CONSTRUCTION CO., LTD., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )
No. 04-711C (Judge C. Miller)
DEFENDANT'S UNOPPOSED MOTION FOR STAY OF PROCEEDINGS Defendant respectfully requests that the Court stay further proceedings in this action in order to allow the parties to continue settlement discussions. On September 22, 2004,
defendant's counsel discussed this request with plaintiff's counsel, who indicated that plaintiff will not oppose the Government's motion. Defendant believes it would be in the interest of the parties and of judicial economy to stay this case so that the parties can continue settlement discussions. Although we expect
that discussions will be completed sooner, in the event that they are not, we propose that the parties file a status report with the Court within 30 days of the requested stay order, informing the Court of the status of our discussions and recommending further action. For this reason, we respectfully request that this Court
Case 1:04-cv-00711-CCM
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Filed 09/23/2004
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grant our motion to stay this case until settlement discussions have concluded. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director
S/ KATHRYN A. BLEECKER KATHRYN A. BLEECKER Assistant Director
S/ KELLY B. BLANK KELLY B. BLANK Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, DC 20530 Tel. (202) 307-1011 Fax. (202) 514-8624 September 23, 2004 Attorneys for Defendant
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Case 1:04-cv-00711-CCM
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Filed 09/23/2004
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CERTIFICATE OF FILING I hereby certify that on September 23, 2004, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR 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. the Court's system. /s/ KELLY B. BLANK Parties may access this filing through