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7/29/2019 Fast and Furious Delay Motion
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
COMMITTEE ON OVERSIGHT AND )
GOVERNMENT REFORM, )UNITED STATES HOUSE OF )
REPRESENTATIVES, ))
Plaintiff, )
) Case No. 1:12-cv-1332 (ABJ)v. )
)
ERIC H. HOLDER, JR., )
in his official capacity as )Attorney General of the United States, )
)Defendant. )___________________________________ )
CONSENT MOTION TO RESCHEDULE ORAL ARGUMENT
Defendant hereby moves to reschedule oral argument on its Motion to Dismiss, currently
scheduled for February 7, 2013, in order to facilitate ongoing settlement talks between the
parties. Counsel for defendant has conferred with counsel for plaintiff pursuant to Local Civil
Rule 7(m), and counsel for plaintiff indicates that plaintiff concurs with the requested relief.
Following the January 10, 2013, Status Conference, the parties have continued to engage
in settlement talks. Without divulging the substance of those talks, the talks are progressing
sufficiently such that the parties believe that further talks may be fruitful. Accordingly, the
parties believe that, in order to enable the parties to focus their efforts on settlement and avoid
the potentially unnecessary expenditure of judicial resources, the hearing on the Motion to
Dismiss should be rescheduled for the week of April 15, 2013, or at such other time as may be
convenient for the Court and the parties. The parties will submit a joint status report to the Court
Case 1:12-cv-01332-ABJ Document 38 Filed 01/29/13 Page 1 of 3
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on March 15, 2013, in order to keep the Court informed as to the progress of the ongoing
settlement negotiations.
For the foregoing reasons, defendant respectfully requests that oral argument on
defendants Motion to Dismiss, currently scheduled for February 7, 2013, be rescheduled for the
week of April 15, 2013.
Dated: January 29, 2013 Respectfully submitted,
STUART F. DELERYPrincipal Deputy Assistant Attorney General
IAN HEATH GERSHENGORNDeputy Assistant Attorney General
JOSEPH H. HUNTDirector, Federal Programs Branch
JOHN R. TYLER
Assistant Branch Director
/s/ Eric Womack
ERIC R. WOMACK(IL Bar No. 6279517)
GREGORY DWORKOWITZ
(NY Bar Registration No. 4796041)LUKE M. JONES
(VA Bar No. 75053)
Trial Attorneys
U.S. Department of JusticeCivil Division
Federal Programs Branch
Washington, D.C. 20001Tel: (202) 514-4020
Fax: (202) 616-8470
Counsel for Defendant
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CERTIFICATE OF SERVICE
I hereby certify that on January 29, 2013, I caused a true and correct copy of the
foregoing Motion and accompanying Proposed Order to be served on plaintiffs counsel
electronically by means of the Courts ECF system.
/s/ Eric Womack
ERIC R. WOMACK
Case 1:12-cv-01332-ABJ Document 38 Filed 01/29/13 Page 3 of 3