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

Case 1:04-cv-00471-EJD

Document 27

Filed 07/21/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ______________________________________________ ) J.H. PARKER CONSTRUCTION COMPANY, INC. ) ) Case No. 04-471C Plaintiff, ) (Chief Judge Damich) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) ______________________________________________) PLAINTIFF'S UNOPPOSED MOTION FOR STAY OF PROCEEDINGS Plaintiff, J.H. Parker Construction Company, Inc. ("Parker"), respectfully requests that the Court stay all proceedings in this case. Counsel for the United States has authorized counsel for Parker to represent that the United States does not oppose this motion. Parker has made a settlement offer, and counsel for the United States has stated that he will recommend that such offer be accepted by the authorized representative of the Attorney General. A stay is in the interests of justice and judicial economy. The parties are optimistic that a settlement has been reached. However, time will be needed for the authorized representative of the Attorney General to consider the offer and, if the offer is accepted, for the necessary formalities to be completed. Currently, the parties are scheduled to devote enormous resources to discovery and pretrial activities in the following week and weeks. All such resources will be wasted if the settlement is approved. Therefore, we respectfully request that our unopposed motion for stay be granted.

Case 1:04-cv-00471-EJD

Document 27

Filed 07/21/2006

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DATED:

July 21, 2006.

Respectfully submitted, J.H. PARKER CONSTRUCTION COMPANY, INC. By Counsel, s/- Harish C. Mirchandani For Carter B. Reid (Attorney of Record) Watt, Tieder, Hoffar & Fitzgerald, L.L.P. 8405 Greensboro Drive, Suite 100 McLean, Virginia 22102 Phone: (703) 749-1000 Fax: (703) 893-8029

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Case 1:04-cv-00471-EJD

Document 27

Filed 07/21/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on July 21, 2006, a true and correct copy of the foregoing Plaintiff'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. Parties may access this filing through the Court's system.

s/ Harish C. Mirchandani For Carter B. Reid

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