Franklin-Mason v. Johnson

District of Columbia, dcd-1:2003-cv-00945

Consent MOTION to Stay re [169] Bill of Costs by ROXANN J. FRANKLIN-MASON

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA) ROXANN J. FRANKLIN-MASON)) Plaintiff,)) v.) Civil Action No. 03-0945 JEB) RAY MABUS) Secretary of the Navy,)) Defendant.)) CONSENT MOTION FOR STAY ON RULING ON DEFENDANT'S BILL OF COSTS COMES NOW, plaintiff, Roxann Franklin-Mason, by and through her undersigned counsel, and hereby respectfully submits this request for a stay of the Court's ruling on defendant's Bill of Costs. The reasons for this request are as follows: Undersigned counsel has consulted with counsel for defendant, and defendant consents to the relief requested. Following the second trial in this matter, defendant filed a Bill of Costs after then entry of judgment in its favor. Meanwhile, plaintiff filed a Notice of Appeal and the Court held in abeyance a ruling on the Bill of Costs while plaintiff exhausted her appeals. Plaintiff's appeals appear now to be exhausted, and the parties have agreed to enter into negotiations to settle the Bill of Costs. Accordingly, the parties agree that any ruling by the Court should be stayed or held in abeyance for two weeks while the parties attempt to settle the issue. Plaintiff proposes that any ruling be stayed until October 25, 2019, and that the parties file a status report on that date to apprise the Court of the status of settlement. 1 Respectfully submitted, ROBINSON BROG LEINWAND GREENE GENOVESE & GLUCK, P.C. By: /s/ Lisa Alexis Jones Lisa Alexis Jones, Esq. 875 Third Avenue 9th Floor New York, N.Y. 10022 (212) 603-6344 laj@robinsonbrog.com Counsel for Plaintiff Dated: October 13, 2019 CERTIFICATE OF SERVICE I hereby certify that on this 13th day of October 2019, I caused to be sent, via electronic mail a copy of the foregoing Motion to Stay to: Christopher Hair, Esq. Fred Haynes, Esq. Assistant United States Attorney Civil Division 555 4th Street, N.W. Washington, D.C. 20530 /s/ Lisa Alexis Jones Lisa Alexis Jones 2