Doe v. United States Air Force et al

Filing 23

MOTION for Hearing by John Doe. (Bosarge, James)

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Case 2:07-cv-00842-RDP Doe v. United States Air Force et al Document 23 Filed 10/29/2007 Page 1 of 2 FILED 2007 Oct-29 PM 03:54 U.S. DISTRICT COURT N.D. OF ALABAMA Doc. 2 IN THE UNITED STATES DISTRICT COURT, NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION JOHN DOE, an individual, Plaintiff, ) ) ) v. ) CASE NO. CV-07-P -0842 -S ) The UNITED STATES AIR FORCE, a ) government agency d/b/a USAF XOI -RE, or ) d/b/a The AIR INTELLIGENCE AGENCY, ) a/k/a A.I.A.; et al. ) ) MOTION TO REQUEST HEARING ON MOTION TO DISMISS AND MOTION FOR SUMMARY JUDGMENT Comes now the Plaintiff, John Doe, by and through his attorney of record, James R. Bosarge, Jr. and requests this Honorable Court set this matter for hearing and shows the following for the relief herein requested: 1. That on October 12, 2007 the Defendants filed a Motion To Dismiss and Motion for Summary Judgment. 2. That on October 26, 2007 the Plaintiff filed his responsive submission to the Defendant's Motion To Dismiss,.... 3. That your Movant contends that this matter needs to be set for a hearing before this Honorable Court wherein the Plaintiff will be afforded the opportunity to present evidence to this Court. 4. That your Movant believes it to be in the best interest of all parties to present said evidence in a court room setting before this Honorable Court. 5. That your Movant contends that this Court will better understand the ramifications of this case once a hearing is held and he is given the opportunity to present evidence in person rather than only written Case 2:07-cv-00842-RDP Document 23 Filed 10/29/2007 Page 2 of 2 communication. WHEREFORE PREMISES CONSIDERED, Your Movant prays that this matter will be set for a hearing at a time convenient to all parties and the Court wherein the Plaintiff and Defendants can appear before this Honorable Court and give testimony and present evidence to this Honorable Court in the pursuit of this matter to be litigated. Your Movant prays for all other such general and different relief as may be required in equity and good conscience. Respectfully submitted, ________s/James R. Bosarge, Jr. ____ James R. Bosarge, Jr., Esquire THE BOSARGE LAW FIRM P.C. 2015 First Avenue North Birmingham, Alabama 35203 (205) 458-1103 CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the foregoing on counsel for the Defendants, Edward Q. Ragland, Assistant United States Attorney, 1801 Fourth Avenue North, Birmingham, Alabama 35203 utilizing the EMCEF filing system on this the ____ day of October, 2007. ___s/James R. Bosarge, Jr. _______ James R. Bosarge, Jr, Esquire

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