Scribd
Upload
157 views2 pages

013 - Motion For Relief

The United States of America filed a motion requesting relief from a court order requiring a scheduling conference and report, and requesting a stay of discovery. The motion argues that discovery should be stayed while the United States' pending motion to dismiss is pending. The motion was filed on January 30, 2018 by the United States Department of Justice in response to a lawsuit filed by Bruce Joiner against the United States.

Uploaded by

Shannon
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
157 views2 pages

013 - Motion For Relief

The United States of America filed a motion requesting relief from a court order requiring a scheduling conference and report, and requesting a stay of discovery. The motion argues that discovery should be stayed while the United States' pending motion to dismiss is pending. The motion was filed on January 30, 2018 by the United States Department of Justice in response to a lawsuit filed by Bruce Joiner against the United States.

Uploaded by

Shannon
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
You are on page 1/ 2

Case 3:17-cv-02692-S Document 13 Filed 01/30/18 Page 1 of 2 PageID 224

UNITED STATES DISTRICT COURT


NORTHERN DISTRICT OF TEXAS

BRUCE JOINER, )
)
Plaintiff, )
)
v. )
) Case No. 3:17-cv-02692
UNITED STATES OF AMERICA, )
)
Defendant. )
____________________________________)

DEFENDANT UNITED STATES OF AMERICA’S MOTION FOR RELIEF FROM


ORDER REQUIRING A SCHEDULING CONFERENCE AND REPORT
AND FOR A STAY OF DISCOVERY

Defendant United States of America respectfully moves this Court to relieve the parties

from the reporting requirements set forth in the Court’s order dated January 16, 2018 (Dkt. # 12),

to abstain from entering a scheduling order, and for a stay of discovery while the United States’

motion to dismiss (Dkt. ## 8, 9, 10) is pending. The grounds for the relief sought in this motion

are set forth in the accompanying memorandum in support.

Dated: January 30, 2018 Respectfully submitted,

CHAD READLER
Acting Assistant Attorney General

JAMES G. TOUHEY, JR.


Director, Torts Branch
Civil Division

RUPERT M. MITSCH
Assistant Director, Torts Branch
Civil Division

United States’ Motion for Relief From Order Requiring Scheduling Report and for Stay of Discovery- 1
Case 3:17-cv-02692-S Document 13 Filed 01/30/18 Page 2 of 2 PageID 225

/s/ Phil MacWilliams


PHILIP D. MACWILLIAMS
Trial Attorney
E-mail: [email protected]
U.S. Department of Justice
Civil Division, Torts Branch
1331 Pennsylvania Ave., NW
Room 8080N
Washington, DC 20004
Telephone: (202) 616-4285
Facsimile: (202) 616-5200

Attorneys for the United States of America

CERTIFICATE OF CONFERENCE

In accordance with Local Rule 7.1, the undersigned conferred with counsel for Plaintiff

on January 26, 2018, who opposes the relief sought in this motion.

/s/ Phil MacWilliams


PHILIP D. MACWILLIAMS

CERTIFICATE OF SERVICE

I hereby certify that on January 30, 2018, I caused to be served upon the following

counsel a true and correct copy of the United States’ Motion For Relief From Scheduling Report

and For A Stay of Discovery and the accompanying memorandum in support via ECF filing:
Trenton Roberts
Roberts & Willie, PLLC
2000 S. Dairy Ashford, Suite 390
Houston, Texas 77077
Phone: (832) 328-7345
Email: [email protected]
Attorney for Plaintiff
/s/ Phil MacWilliams
PHILIP D. MACWILLIAMS

United States’ Motion for Relief From Order Requiring Scheduling Report and for Stay of Discovery- 2

You might also like