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

Case 1:07-cv-00544-MMS

Document 62

Filed 11/15/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS MEEKS DISPOSAL CORPORATION, Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant, and DORADO SERVICES, INC., Defendant-Intervenor. ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Bid Protest No.07-544C (Judge Sweeney)

UNOPPOSED MOTION TO WITHDRAW COMES NOW Plaintiff Meeks Disposal Corporation (hereinafter "Meeks"), by counsel, and respectfully withdraw its Motions to Compel Reliable Trash Service, LLC and Waste Industries, LLC (hereinafter "Nonparties") from the telephonic hearing scheduled for Wednesday, November 14, 2007. In support of this Motion, Meeks states as follows: 1. Nonparties. 2. 3. Counsel for Nonparties consents to this unopposed Motion. Counsel for Meeks has contacted counsel for Defendant and DefendantOn November 13, 2007, an agreement was reached between Meeks and

Intervenor and they also consent to this unopposed Motion. WHEREFORE, it is prayed that this Court withdraw the Motions to Compel Nonparties Reliable Trash Services, LLC and Waste Industries, LLC from the docket.

Case 1:07-cv-00544-MMS

Document 62

Filed 11/15/2007

Page 2 of 2

Respectfully submitted this 15th day of November, 2007. MEEKS DISPOSAL CORPORATION

By:

/s/ J. Bryan Plumlee Of Counsel

J. Bryan Plumlee, Esq. (VSB# 44444) Paul R. Schmidt, Esq. (VSB# 45840) HUFF, POOLE & MAHONEY, P.C. Counsel for Meeks Disposal Corporation 4705 Columbus Street Virginia Beach, Virginia 23462 Telephone: (757) 518-5615 Facsimile: (757) 552-6016 [email protected] CERTIFICATE OF SERVICE The Plaintiff hereby certifies that on the 15th day of November, 2007, I will electronically file the foregoing Unopposed Motion to Withdraw using the CM/ECF system, which will then send a notification of such filing to the following: F. Jefferson Hughes, Esq. Department of Justice Commercial Litigation Branch, Civil Division 8th Floor 100 L. Street, N.W. Washington, DC 20530 Joseph M. Goldstein, Esq. Shutts & Bowen, LLP 200 East Broward Blvd. Suite 2100 Ft. Lauderdale, FL 33301 Jennifer Miller, Esq. Wyrick Robbins Yates & Ponton LLP 4101 Lake Boone Trail Suite 300 Raleigh, NC 27607

/s/ J. Bryan Plumlee Of Counsel

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