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

Case 1:99-cv-00121-JFM

Document 87

Filed 01/11/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS FORD MOTOR COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 99-121C (Judge Merow)

DEFENDANT'S UNOPPOSED MOTION FOR STAY PENDING POTENTIAL SETTLEMENT Pursuant to Rules 6 and 6.1 of the Court's Rules ("RCFC"), defendant, the United States, respectfully requests the Court to stay pretrial proceedings in this matter. Nicholas Oldham,

counsel for Ford Motor Company, states that Ford does not oppose a stay. Pursuant to the Court's order dated November 21, 2005,

the parties' pretrial filings pursuant to RCFC Appendix A are due on January 17, 2006. Trial is scheduled for February 6, 2006.

However, counsel have agreed in principle upon a settlement proposal which is currently under consideration by the appropriate officials within the Department of Justice. The

parties will inform the Court immediately of the acceptance or rejection of the proposal. Respectfully submitted, PETER D. KEISLER Assistant Attorney General s/ DAVID M. COHEN Director

Case 1:99-cv-00121-JFM

Document 87

Filed 01/11/2006

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OF COUNSEL: JOHN LAURO Attorney Air Force Legal Services Agency Arlington, VA s/Kyle Chadwick KYLE CHADWICK Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Tele: (202) 305-7562 Fax: (202) 305-7644 Attorneys for Defendant January 11, 2006

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Case 1:99-cv-00121-JFM

Document 87

Filed 01/11/2006

Page 3 of 3

CERTIFICATE OF FILING I certify that on January 11, 2006, I filed the attached document by means of the Court's electronic filing system. Opposing counsel and others may access the filing through the Court's system. s/Kyle Chadwick

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