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STEINBUCH v. CUTLER - Document No. 85

STEINBUCH v. CUTLER - Document No. 85

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Published by Justia.com
Consent MOTION to Stay Discovery by ANA MARIE COX. (Attachments: # 1 Text of Proposed Order)(Handman, Laura) 1:2005cv00970 District Of Columbia District Court
Consent MOTION to Stay Discovery by ANA MARIE COX. (Attachments: # 1 Text of Proposed Order)(Handman, Laura) 1:2005cv00970 District Of Columbia District Court

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Published by: Justia.com on Apr 30, 2008
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10/14/2013

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
ROBERT STEINBUCH,
))
Plaintiff,
))
v.
)
Civil ActionNo. 1:05cv970 (PLF)(JMF)
)
JESSICA CUTLER
)
and
)
ANA MARIE COX,
))
Defendants.
)
CONSENT MOTION FOR STAY OF DISCOVERY
Defendant Ana Marie Cox ( Cox ) hereby movesfor a stay of discoveryin this case
pendingthe Court s rulingon her Motion to Dismiss.

On May 16, 2005, Plaintiff Robert Steinbuch ( Plaintiff ) filed his original Complaint, naming Defendant Jessica Cutler ( Cutler ) as the sole defendant. On July 9, 2006, Plaintiff filed a motion for leave to amend his Complaint in order to add Cox as a defendant, and the

Court granted his motion on October 30, 2006.
Cox was served on January 6, 2007. On January
26, 2007, Cox filed her Motion to Dismiss Plaintiff s First Amended Complaint for failure to
state a claim upon which relief can be granted, pursuant to Federal Rule of Civil Procedure
12(b)(6).
Cox requests that this Court stay all discovery with respect to her until the Court has
decided her Motion to Dismiss. Because the motion may result in the dismissal of Plaintiff s
claims against Cox in their entirety, it would unfairly prejudice Cox to impose the time and costs

of discovery on her before the motion is resolved. It could also waste the other parties resources to take potentially unnecessary discovery and should disputes arise concerning such discovery which require the Court s interventionitwould squander judicial resources as well.

Case 1:05-cv-00970-PLF-JMF Document 85
Filed 01/26/2007 Page 1 of 4
STEINBUCH v. CUTLER
Doc. 85
Dockets.Justia.com
2
Counsel for Coxhas consulted with counsel for Plaintiffand counsel for Cutler, who
haveconsented tothis motion.Counsel for Plaintiff has authorized us to state that he consents to
a stay of all proceedings; counsel for Cutler has authorized us to state that Cutler consents to a
stay of discovery, but not of the briefing and disposition of Cutler s pending motion. In sum, all
parties are in agreement that discovery should be stayed pending resolution of this motion and
the disagreement between the other two parties regarding the scope of the stay is immaterial for
purposes of this stay motion.
Dated this 26th day of January, 2007.
Respectfully submitted,
/s/ Laura R. Handman
Laura R. Handman (D.C. Bar No. 444386)
Amber L. Husbands (D.C. Bar No.481565)
DAVIS WRIGHT TREMAINE LLP
1500 K Street, N.W., Suite 450
Washington, D.C. 20005-1272
(202) 508-6600
(202) 508 6699 fax
James Rosenfeld (pro hac viceapplication
pending)
DAVIS WRIGHT TREMAINE LLP
1633 Broadway,27th Floor
New York, N.Y. 10019
(212) 489-8230
(212) 489-8340 fax
Charles R. Both(D.C. Bar No. 42424)
Law Offices of Charles R. Both
1666 Connecticut Avenue
Suite 500
Washington, D.C. 20009
(202) 833-9060
(202) 463-6686 (fax)
Attorneys for Defendant AnaMarie Cox
Case 1:05-cv-00970-PLF-JMF Document 85
Filed 01/26/2007 Page 2 of 4
3
STATEMENT OF CONSENT
Pursuant to Local Civil Rule 7.1(m), undersigned counsel hereby states that the required
discussion with counsel for plaintiff occurred onJanuary 25, 2007, and that counsel for Plaintiff
does not oppose this motion.The required discussion with counsel for Defendant Cutler
occurred on January 24, 2007, and counsel for Cutler does not oppose this motion.
/s/ James Rosenfeld
James Rosenfeld
Case 1:05-cv-00970-PLF-JMF Document 85
Filed 01/26/2007 Page 3 of 4

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