"Should the Court conclude that a stay pending resolution of the D.C. Circuit appeals is not warranted, then we respectfully request that the Court temporarily stay proceedings to permit full briefing on the separate motion to dismiss we would file based on Judge Lamberth’s decision and its preclusive effects. The district court’s resolution of identical claims as matter of law militates in favor of, at the very least, temporarily halting discovery to consider the exact same dispositive legal issues here. "