LYTTLE v. The UNITED STATES OF AMERICA et al

Filing 89

Supplemental MOTION to Stay by Mark Daniel Lyttle. (Attachments: # 1 Text of Proposed Order) (Reyes, Alexandria)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
EASTERN DIVISION
Case No. 4:10-cv-142-D
____________________________________
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MARK DANIEL LYTTLE,
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)
Plaintiff,
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PLAINTIFF’S UNOPPOSED
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MOTION TO EXTEND STAY
v.
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UNITED STATES OF AMERICA, et al., )
)
Defendants.
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____________________________________)
PLAINTIFF’S UNOPPOSED MOTION TO EXTEND STAY
Plaintiff Mark Daniel Lyttle, by and through counsel, moves this Court to extend the stay
entered in this case through and including November 13, 2012. In support of this motion,
Plaintiff states as follows:
1.

On July 27, 2012, the parties jointly moved to stay this case to allow the parties

to continue settlement discussions and finalize settlement documents. [ECF Doc. No. 87.]
2.

Also on July 27, 2012, this Court entered an order staying this case through and

including September 14, 2012. [ECF Doc. No. 88.]
3.

Since the Court stayed this case, the parties have continued their good-faith

efforts to pursue and finalize settlement. While the parties have agreed in principle to a
settlement of all claims against all remaining federal defendants, including the United States of
America and all individually-named federal defendants, the parties are continuing to work to
finalize certain key provisions of the proposed settlement agreement.

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4.

The parties are optimistic that they will be able to reach and execute a final

settlement agreement and related documents with the benefit of a stay of an additional sixty (60)
days.
5.

Plaintiff is authorized to state that counsel for the remaining defendants consents

to this request to extend the stay.
6.

Accordingly, Plaintiff respectfully requests an extension of the stay for an

additional sixty (60) days, through and including November 13, 2012.

Respectfully submitted this 12th day of September, 2012.

/s/ Alexandria J. Reyes
Michael E. Johnson
Georgia Bar No. 395039
[e-mail]
Brian P. Watt
Georgia Bar No. 741841
[e-mail]
Alexandria J. Reyes
Georgia Bar No. 428936
[e-mail]
Bank of America Plaza, Suite 5200
600 Peachtree Street, N.E.
Atlanta, Georgia 30308-2216
Attorneys for Plaintiff Mark Daniel Lyttle

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CERTIFICATE OF SERVICE
I hereby certify that on this day, I electronically filed the foregoing Plaintiff’s
Unopposed Motion to Extend Stay with the Clerk of Court using the Court’s CM/ECF system,
which will send notification of such filing to all parties of record.
This 12th day of September, 2012.

/s/ Alexandria J. Reyes
Alexandria J. Reyes
Georgia Bar No. 428936
[e-mail]
Bank of America Plaza, Suite 5200
600 Peachtree Street, N.E.
Atlanta, Georgia 30308-2216
Attorneys for Plaintiff Mark Daniel Lyttle

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