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

Case 1:03-cv-02673-EJD

Document 74

Filed 08/01/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) ALLIED OIL & SUPPLY, INC., ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) No. 03-2673C ) Defendant, ) (Chief Judge Damich) ) and ) ) WARREN DISTRIBUTION, INC., ) ) Third-Party Defendant ) ____________________________________)

DEFENDANT'S UNOPPOSED MOTION FOR A STAY OF PROCEEDINGS Defendant, the United States, respectfully requests the Court to stay proceedings, through and including August 24, 2007, to allow the parties to finalize a settlement agreement. The parties have agreed to a settlement of this suit, however, additional time is needed to prepare and obtain signatures for the settlement agreement. Counsel for plaintiff Allied Oil & Supply, Inc. ("Allied") and counsel for Warren Distribution, Inc. ("Warren") have indicated that Allied and Warren are not opposed to this motion. For these reasons, we respectfully request a stay of proceedings through and including August 24, 2007.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

Case 1:03-cv-02673-EJD

Document 74

Filed 08/01/2007

Page 2 of 2

/s/ Deborah A. Bynum DEBORAH A. BYNUM Assistant Director /s/ Michael J. Dierberg MICHAEL J. DIERBERG Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Fl. 1100 L St. NW Washington, DC 20530 Telephone: (202) 353-0536 Facsimile: (202) 307-0972 Dated: August 1, 2007 Attorneys for Defendant