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

Case 1:07-cv-00632-RHH

Document 7

Filed 08/28/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS NAS/CORP-TELMAH, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-632C (Judge Robert H. Hodges, Jr.)

UNOPPOSED MOTION TO STAY CASE Pursuant to Rule 7 and Appendix C of the Rules of this Court, the United States respectfully requests that the Court issue an order staying the above-captioned case in order to allow the parties time to reach a settlement. Plaintiff does not oppose this motion. We note that although the contract awardee already has delivered to the Government the ultrasonic surgical aspirator at issue ­ and thus the protested procurement is substantially complete ­ counsel nonetheless has instructed the contracting officer not to permit the item to be used until further notice and to notify counsel if a medical emergency necessitates the item's use.

Respectfully submitted,

PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

Case 1:07-cv-00632-RHH

Document 7

Filed 08/28/2007

Page 2 of 3

s/ Bryant G. Snee BRYANT G. SNEE Deputy Director

Dated: August 28, 2007

s/ Matthew H. Solomson MATTHEW H. SOLOMSON Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 Tel: 202.305.3274 Fax: 202.514.8624 [email protected]

-2-

Case 1:07-cv-00632-RHH

Document 7

Filed 08/28/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that, on this 28th day of August 2007, a copy of the foregoing UNOPPOSED MOTION TO STAY CASE 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/ Matthew H. Solomson MATTHEW H. SOLOMSON