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

Case 1:08-cv-00087-SGB

Document 13

Filed 03/06/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS WESTON SOLUTIONS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 08-87C (Judge Braden)

JOINT MOTION TO STAY

Defendant, United States, and Plaintiff, Weston Solutions, Inc., respectfully request that the Court stay the proceedings in this case for thirty days, until April 3, 2008. Counsel of record for the United States has received a written offer of settlement from the plaintiff, which will be presented to the Authorized Representative of the Attorney General for consideration. The proposed stay will allow counsel for both parties sufficient opportunity to discuss this matter with respective clients and to work out the terms of a settlement, should that occur. We respectfully request, therefore, that the Court grant our joint motion to stay until April 3, 2008. In the event that a settlement has not been concluded by then, the parties propose to file a joint status report on April 3, 2008, regarding the status of settlement activities.

Case 1:08-cv-00087-SGB

Document 13

Filed 03/06/2008

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Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director

s/ Michael H. Payne MICHAEL H. PAYNE Payne Hackenbracht & Sullivan 220 Commerce Dr., Suite 100 Ft. Washington, PA 19034 tel: (215) 542-2777 fax: (219) 542-2779

s/ Joseph A. Pixley JOSEPH A. PIXLEY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 307-0843 Fax: (202) 307-0972 Attorneys for Defendant

Attorney for Plaintiff March 6, 2008

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Case 1:08-cv-00087-SGB

Document 13

Filed 03/06/2008

Page 3 of 3

CERTIFICATE OF FILING

I hereby certify that on the 6th day of March, 2008, a copy of the foregoing "JOINT MOTION TO STAY" 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/Joseph A. Pixley

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