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

Case 1:04-cv-00497-LMB

Document 64

Filed 06/21/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JANELLE HOHNKE, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 04-0497C (Judge Baskir)

JOINT MOTION TO STAY Pursuant to Rule 1 of the Rules of the United States Court of Federal Claims, the parties respectfully request that the Court stay this action for a period of 60 days. In support of this motion, the parties state that they have entered into a settlement agreement. The parties anticipate that the settlement agreement will be fully performed within 60 days, at which time the parties will dismiss this action. Accordingly, granting this motion will be in the interests of judicial economy, as trial is scheduled for the week of July 9, 2007. Respectfully submitted, s/Brenda Lewison BRENDA LEWISON Law Office of Arthur Heitzer 633 West Wisconsin Avenue Suite 1410 Milwaukee, WI 53203 (414) 273-1040 PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Mark A. Melnick MARK A. MELNICK Assistant Director

Case 1:04-cv-00497-LMB

Document 64

Filed 06/21/2007

Page 2 of 3

s/Michael N. O'Connell MICHAEL N. O'CONNELL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 (202) 353-1618 (202) 514-8624 (fax) DATED: June 21, 2007

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Case 1:04-cv-00497-LMB

Document 64

Filed 06/21/2007

Page 3 of 3

Certificate of Filing I hereby certify that on this 21st day of June, 2007, a copy of the foregoing joint status report 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. s/ Michael N. O'Connell