Docket Item 21 Dcd 08-cv-2234 Us Motion To Stay Discovery 060909
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Case 1:08-cv-02234-RJL
Document 21
Filed 06/09/2009
Page 1 of 3
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
CHRISTOPHER EARL STRUNK, Plaintiff, v.
Case No. 1:08-CV-02234 (RJL)
U.S. DEPARTMENT OF STATE, U.S. DEPARTMENT OF HOMELAND SECURITY, Defendants.
DEFENDANTS’ MOTION FOR STAY OF DISCOVERY Defendants hereby respectfully move the Court to stay any and all discovery until the pending cross-motions to dismiss [Dkt. #16] and for jury proceedings [Dkt. #19] have been resolved and a scheduling order governing the remaining portions of this action has been established. The grounds warranting the entry of a stay are set forth in Defendants’ June 8, 2009 consolidated filing [Dkt. #20].1
Dated: June 9, 2009
Respectfully submitted, TONY WEST Assistant Attorney General ELIZABETH J. SHAPIRO (D.C. Bar No. 418925) Deputy Branch Director /s/ Brigham J. Bowen BRIGHAM J. BOWEN (D.C. Bar No. 981555) Civil Division, U.S. Department of Justice
1
Pursuant to LCvR 7(m), counsel has conferred with Plaintiff is informed that Plaintiff opposes this motion.
Case 1:08-cv-02234-RJL
Document 21
Filed 06/09/2009
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Federal Programs Branch P.O. Box 883, 20 Massachusetts Ave., N.W. Washington, D.C. 20044 (202) 514-6289 [email protected] Counsel for Defendants
2
Case 1:08-cv-02234-RJL
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CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 9th day of June, 2009, a true and correct copy of the foregoing Motion for Stay of Discovery was served upon Plaintiff by first class United States mail, postage prepaid marked for delivery to:
Christopher E. Strunk 593 Vanderbilt Ave., #281 Brooklyn, NY 11238 /s/ Brigham J. Bowen Brigham J. Bowen
3
Case 1:08-cv-02234-RJL
Document 21-2
Filed 06/09/2009
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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
CHRISTOPHER EARL STRUNK, Plaintiff, v.
Case No. 1:08-CV-02234 (RJL)
U.S. DEPARTMENT OF STATE, U.S. DEPARTMENT OF HOMELAND SECURITY, Defendants.
[PROPOSED] ORDER [#__] Before the Court are (1) Defendants’ Partial Motion to Dismiss Plaintiff’s Amended Complaint; (2) Plaintiff’s Motion for Quo Warranto Proceedings; and (3) Defendants’ Motion for a Stay of Discovery. For the reasons set forth in Defendants’ motions, the Court GRANTS Defendants’ motions and denies Plaintiff’s motion. All claims regarding records concerning or regarding President Barack H. Obama are hereby DISMISSED WITH PREJUDICE; Plaintiff’s motion for quo warranto proceedings and other relief is DENIED; and Defendants’ motion for a stay of discovery is GRANTED. No discovery shall take place until further order of the Court. SO ORDERED.
June __, 2009
___________________________ RICHARD J. LEON United States District Judge
Document 21
Filed 06/09/2009
Page 1 of 3
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
CHRISTOPHER EARL STRUNK, Plaintiff, v.
Case No. 1:08-CV-02234 (RJL)
U.S. DEPARTMENT OF STATE, U.S. DEPARTMENT OF HOMELAND SECURITY, Defendants.
DEFENDANTS’ MOTION FOR STAY OF DISCOVERY Defendants hereby respectfully move the Court to stay any and all discovery until the pending cross-motions to dismiss [Dkt. #16] and for jury proceedings [Dkt. #19] have been resolved and a scheduling order governing the remaining portions of this action has been established. The grounds warranting the entry of a stay are set forth in Defendants’ June 8, 2009 consolidated filing [Dkt. #20].1
Dated: June 9, 2009
Respectfully submitted, TONY WEST Assistant Attorney General ELIZABETH J. SHAPIRO (D.C. Bar No. 418925) Deputy Branch Director /s/ Brigham J. Bowen BRIGHAM J. BOWEN (D.C. Bar No. 981555) Civil Division, U.S. Department of Justice
1
Pursuant to LCvR 7(m), counsel has conferred with Plaintiff is informed that Plaintiff opposes this motion.
Case 1:08-cv-02234-RJL
Document 21
Filed 06/09/2009
Page 2 of 3
Federal Programs Branch P.O. Box 883, 20 Massachusetts Ave., N.W. Washington, D.C. 20044 (202) 514-6289 [email protected] Counsel for Defendants
2
Case 1:08-cv-02234-RJL
Document 21
Filed 06/09/2009
Page 3 of 3
CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 9th day of June, 2009, a true and correct copy of the foregoing Motion for Stay of Discovery was served upon Plaintiff by first class United States mail, postage prepaid marked for delivery to:
Christopher E. Strunk 593 Vanderbilt Ave., #281 Brooklyn, NY 11238 /s/ Brigham J. Bowen Brigham J. Bowen
3
Case 1:08-cv-02234-RJL
Document 21-2
Filed 06/09/2009
Page 1 of 1
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
CHRISTOPHER EARL STRUNK, Plaintiff, v.
Case No. 1:08-CV-02234 (RJL)
U.S. DEPARTMENT OF STATE, U.S. DEPARTMENT OF HOMELAND SECURITY, Defendants.
[PROPOSED] ORDER [#__] Before the Court are (1) Defendants’ Partial Motion to Dismiss Plaintiff’s Amended Complaint; (2) Plaintiff’s Motion for Quo Warranto Proceedings; and (3) Defendants’ Motion for a Stay of Discovery. For the reasons set forth in Defendants’ motions, the Court GRANTS Defendants’ motions and denies Plaintiff’s motion. All claims regarding records concerning or regarding President Barack H. Obama are hereby DISMISSED WITH PREJUDICE; Plaintiff’s motion for quo warranto proceedings and other relief is DENIED; and Defendants’ motion for a stay of discovery is GRANTED. No discovery shall take place until further order of the Court. SO ORDERED.
June __, 2009
___________________________ RICHARD J. LEON United States District Judge
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