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1:11-cv-1190 #38

1:11-cv-1190 #38

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Published by Equality Case Files
Doc #38 - BLAG's unopposed motion for leave to file consolidated reply in support of motion to intervene.
Doc #38 - BLAG's unopposed motion for leave to file consolidated reply in support of motion to intervene.

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Published by: Equality Case Files on May 15, 2012
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05/15/2012

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MASSACHUSETTS
__________________________________________)SHANNON L. MCLAUGHLIN, et al., ))Plaintiffs, ))v. ) No. 1:11-cv-11905)LEON PANETTA, et al., ))Defendants. )__________________________________________)
UNOPPOSED MOTION OF PROPOSED INTERVENOR-DEFENDANTFOR LEAVE TO FILE CONSOLIDATED REPLY MEMORANDUMIN SUPPORT OF MOTION TO INTERVENE
On May 1, 2012, proposed Intervenor-Defendant the Bipartisan Legal Advisory Group of the United States House of Representatives (“House”) moved for leave to intervene in this matteras a defendant.
See
Mot. of the [House] for Leave to Intervene (May 1, 2012) (ECF No. 32). OnMay 9, 2012, plaintiffs opposed the House’s intervention motion, and on May 15, 2012, theExecutive Branch Defendants responded to the House’s intervention motion.
See
Pls.’ Opp’n tothe Mot. of the [House] for Leave to Intervene (May 9, 2012) (ECF No. 34); Defs.’ Resp. to Mot.of the [House] for Leave to Intervene (May 15, 2012) (ECF No. 37).Pursuant to Local Civil Rule 7.1(b)(3), and for the reasons set forth in the accompanyingMemorandum of Points and Authorities, the House now moves for leave to file one consolidatedreply memorandum, not to exceed 30 pages in length, in support of its intervention motion, andto file said consolidated reply memorandum on or before June 22, 2012.
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While the House may well be able – and will do its best – to file a reply memorandumthat is less than 30 pages in length, it is difficult to judge at this point how many pages actually
(
Continued . . .
)
Case 1:11-cv-11905-RGS Document 38 Filed 05/15/12 Page 1 of 4
 
A proposed order is submitted herewith, and oral argument is not requested.Respectfully submitted,Paul D. Clement
 /s/ H. Christopher Bartolomucci
H. Christopher BartolomucciConor B. Dugan
 
Nicholas NelsonBANCROFT PLLC1919 M Street, N.W., Suite 470Washington, D.C. 20036(202) 234-0090 (phone)(202) 234-2806 (fax)cbartolomucci@bancroftpllc.com
Counsel for Proposed Intervenor-Defendant the Bipartisan Legal Advisory Group of the U.S. Houseof Representatives
2
 Of Counsel
Kerry W. Kircher, General CounselWilliam Pittard, Deputy General CounselChristine Davenport, Senior Assistant CounselKirsten W. Konar, Assistant CounselTodd B. Tatelman, Assistant CounselMary Beth Walker, Assistant CounselOffice of General CounselU.S. House of Representatives
 
219 Cannon House Office BuildingWashington, D.C. 20515(202) 225-9700 (phone)(202) 226-1360 (fax) May 15, 2012will be required to respond to plaintiffs’ opus. We are confident, however, that no more than 30pages will be required.
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The Bipartisan Legal Advisory Group currently is comprised of the Honorable John A.Boehner, Speaker of the House, the Honorable Eric Cantor, Majority Leader, the HonorableKevin McCarthy, Majority Whip, the Honorable Nancy Pelosi, Democratic Leader, and theHonorable Steny H. Hoyer, Democratic Whip. The Democratic Leader and Democratic Whiphave declined to support the Group’s underlying motion to intervene in this case.
Case 1:11-cv-11905-RGS Document 38 Filed 05/15/12 Page 2 of 4
 
LOCAL RULE 7.1(A)(2) STATEMENT
On May 15, 2012, undersigned counsel conferred with Jean Lin, Senior Trial Counselwith the Department of Justice, and Christopher Man, counsel for plaintiffs. Both advised thattheir clients do not oppose the relief requested in the foregoing motion.Respectfully submitted,
 /s/ Kerry W. Kircher 
Kerry W. Kircher, General CounselU.S. House of Representatives
Case 1:11-cv-11905-RGS Document 38 Filed 05/15/12 Page 3 of 4

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