IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF FLORIDA
PENSACOLA DIVISION

WARD DEAN,	)
	)
Plaintiff,	)
	)
v.	)	No.3 :03 cv 00065 (LAC/MCR)
	)
UNITED STATES, et al.,	)
	)
Defendants.	)
	)

UNITED STATES' MOTION FOR STAY OF PROCEEDINGS

Defendant, the United States of America, by and through undersigned counsel, moves the Court under Fed. R. Civ. P. 7 and Local Rule 7.1 to issue an order staying this civil proceeding until the conclusion of the Internal Revenue Service's criminal investigation and other criminal proceedings against plaintiff. It is without dispute that the factual allegations of plaintiffs complaint stem from the ongoing investigation of Ward Dean. To that end, Dean now seeks civil discovery that is related to the ongoing criminal investigation and grand jury proceeding, which must be prohibited.

Grounds for this motion are set forth in greater detail in the accompanying memorandum. Also, the Declaration of Special Agent Tanya D. Burgess is provided in support of this motion and is attached as Exhibit A.

Prior to the United States filing this motion and under Local Rule 7.1 (B), Dean was contacted and a good faith attempt was made to resolve the issues raised by this motion. But a resolution was not reached.

WHEREFORE the United States requests the Court to stay this civil action until the
criminal investigation and proceedings against Dean are completed by entering the attached order.

DATED: July 25, 2003
Respectfully submitted,

GREGORY R. MILLER
United States Attorney
LINDSEY, W. COOPER, JR.
(TN Bar No.020 05, DC Bar 473895)
Trial Attorney, Tax Division
U.S. Department of Justice
P .0. Box 227, Ben Franklin Station
Washington, DC 20044
Telephone: (202) 307-6528
Facsimile: (202) 514-6866
Attorney for the United States