Free Motion to Approve Consent Judgment - District Court of Federal Claims - federal

Case 1:01-cv-00056-ECH

Document 253

Filed 02/04/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ________________________________ JOHN BULL, et al., Plaintiffs, v. UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 01-56C Judge Hewitt

JOINT MOTION FOR APPROVAL OF SETTLEMENT Plaintiffs, John Bull, et al., and defendant United States respectfully submit this joint motion for approval of settlement and would respectfully show the Court as follows: The parties, by and through counsel, jointly move the Court for an order granting approval of the settlement in this case. A copy of the Settlement Agreement is attached hereto as Exhibit A. In connection with approval of this settlement, the parties jointly request entry of a stipulated order in the form submitted to the Court. WHEREFORE, the parties respectfully request that the Court grant approval to the proposed settlement and enter an order approving the attorney fees as requested in the Fee Application and Bill of Costs filed by the plaintiffs on July 16, 2007, and agreed upon in the settlement agreement, as reasonable, necessary, appropriate, and fair compensation to plaintiffs' attorneys for their services on behalf of the plaintiffs in this litigation. A proposed order to that effect is attached as Exhibit B.

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Case 1:01-cv-00056-ECH

Document 253

Filed 02/04/2008

Page 2 of 3

Respectfully submitted, S/David L. Kern DAVID L. KERN Kern Law Firm 1300 North El Paso St. El Paso, TX 79902 Tele: (915) 542-1900 Fax: (915) 242-0000 Attorney for Plaintiffs JEFFREY S. BUCHHOLTZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director S/Kirk Manhardt KIRK MANHARDT Assistant Director

S/Tara K. Hogan TARA K. HOGAN Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St. NW Washington, DC 20530 Tele: (202) 616-2228 Fax: (202) 305-7643 Commercial Litigation Branch Attorneys for Defendant Dated: February 4, 2008

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Case 1:01-cv-00056-ECH

Document 253

Filed 02/04/2008

Page 3 of 3

CERTIFICATE OF ELECTRONIC FILING I hereby certify that on February 4, 2008 a copy of foregoing "JOINT MOTION FOR APPROVAL OF SETTLEMENT" 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/Tara K. Hogan

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