UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIA
CAUSE OF ACTION, INC., ))Plaintiff, ))v. ) 1:12-cv-1342 (JEB))NATIONAL ARCHIVES ANDRECORDS ADMINISTRATION,)))
Defendant. )_________________________________________ )
PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION TO DISMISS OR IN THEALTERNATIVE FOR SUMMARY JUDGMENT AND MEMORANDUM OF POINTS ANDAUTHORITIES IN SUPPORT THEREOF AND PLAINTIFF’ S CROSS- MOTION FORSUMMARY JUDGMENT AND MEMORANDUM OF POINTS AND AUTHORITIES INSUPPORT THEREOF
Plaintiff, Cause of Action, respectfully opposes Defendant’s Motion to Dismiss or in thealternative for Summary Judgment (“Def.’s Motion”), and files Plaintiff’s Cross-Motion forSummary Judgment (“Plaintiff’s Cross-Motion”) under Rule 56 of the Federal Rules of CivilProcedure and Local Rule 7(h), and requests that this Court issue an Order denying Defendant’sMotion, and granting Plaintiff’s Motion, thereby issuing judgment in favor of Cause of Action onthe grounds that no genuine issue as to any material fact exists, and Cause of Action is entitled to judgment as a matter of law. Attached in support of Plaintiff’s Cross-Motion are Plaintiff’sMemorandum of Points and Authorities in Support of its Motion for Summary Judgment, andPlaintiff’s Statement of Material Facts Not In Dispute in Support of its Motion for SummaryJudgment. A proposed Order consistent with the relief requested herein is also attached.
REQUEST FOR HEARING
Plaintiff, Cause of Action, hereby respectfully requests, pursuant to Local Rule 7(f), ahearing on its Opposition to Defendant’s Motion to Dismiss, or in the Alternative for SummaryJudgment, and Plaintiff’s Cross-Motion for Summary Judgment.
Case 1:12-cv-01342-JEB Document 11 Filed 12/19/12 Page 1 of 48