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Pursuant to LCvR 7(m), counsel has conferred with Plaintiff is informed that Plaintiff opposes this motion.UNITED STATES DISTRICT COURTFOR 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 HOMELANDSECURITY,Defendants.
DEFENDANTS’ MOTION FOR STAY OF DISCOVERY
Defendants hereby respectfully move the Court to stay any and all discovery until thepending cross-motions to dismiss [Dkt. #16] and for jury proceedings [Dkt. #19] have beenresolved and a scheduling order governing the remaining portions of this action has beenestablished. The grounds warranting the entry of a stay are set forth in Defendants’ June 8, 2009consolidated filing [Dkt. #20].
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Dated: June 9, 2009Respectfully submitted,TONY WESTAssistant Attorney GeneralELIZABETH J. SHAPIRO (D.C. Bar No. 418925)Deputy Branch Director/s/ Brigham J. BowenBRIGHAM J. BOWEN (D.C. Bar No. 981555)Civil Division, U.S. Department of Justice
Case 1:08-cv-02234-RJL Document 21 Filed 06/09/2009 Page 1 of 3
 
2Federal Programs BranchP.O. Box 883, 20 Massachusetts Ave., N.W.Washington, D.C. 20044(202) 514-6289brigham.bowen@usdoj.govCounsel for Defendants
Case 1:08-cv-02234-RJL Document 21 Filed 06/09/2009 Page 2 of 3
 
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CERTIFICATE OF SERVICEI HEREBY CERTIFY
that on this 9th day of June, 2009, a true and correct copy of theforegoing Motion for Stay of Discovery was served upon Plaintiff by first class United Statesmail, postage prepaid marked for delivery to:
Christopher E. Strunk593 Vanderbilt Ave., #281Brooklyn, NY 11238
/s/ Brigham J. BowenBrigham J. Bowen
Case 1:08-cv-02234-RJL Document 21 Filed 06/09/2009 Page 3 of 3
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