Golinski v. United States Office of Personnel Management

Filing 155

Declaration of Rita F. Lin in Support of 154 Reply to Opposition/Response, Of Bipartisan Legal Advisory Group's Opposition To Her Motiobn For Summary Judgment filed byKaren Golinski. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Related document(s) 154 ) (Lin, Rita) (Filed on 7/22/2011)

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From: Lin, Rita F. Sent: Thursday, July 21, 2011 4:42 PM To: 'Christopher Bartolomucci'; 'Hall, Christopher (CIV)' Cc: 'TBorelli@lambdalegal.org' Subject: RE: Golinski: proposed summary judgment schedule Chris, We believe further discovery has not been shown to be necessary, so we will not be withdrawing our summary judgment motion. As I noted in my email, we are presenting this schedule only to allow things to move forward quickly if the Court disagrees. Please let me know what, if anything, we should represent to the Court about your position on the schedule. Thanks, Rita From: Christopher Bartolomucci [mailto:cbartolomucci@bancroftpllc.com] Sent: Thursday, July 21, 2011 11:12 AM To: Hall, Christopher (CIV); Lin, Rita F. Cc: TBorelli@lambdalegal.org Subject: RE: Golinski: proposed summary judgment schedule Rita,    The House is willing to agree to your proposed schedule if you agree to withdraw your motion for  summary judgment by the end of this week.   Thanks,   Chris B.   From: Hall, Christopher (CIV) [mailto:Christopher.Hall@usdoj.gov] Sent: Wednesday, July 20, 2011 1:31 AM To: Christopher Bartolomucci; Lin, Rita F. Cc: TBorelli@lambdalegal.org Subject: RE: Golinski: proposed summary judgment schedule Rita –   I was out of pocket today and not able to take a look at your proposal.  I will aim to do so tomorrow.   Regards, Chris   From: Christopher Bartolomucci [mailto:cbartolomucci@bancroftpllc.com] Sent: Tuesday, July 19, 2011 10:25 AM To: Lin, Rita F.; Hall, Christopher (CIV) Cc: TBorelli@lambdalegal.org Subject: RE: Golinski: proposed summary judgment schedule We will review what you have circulated. Thanks. From: Lin, Rita F. [mailto:RLin@mofo.com] Sent: Tue 7/19/2011 3:29 AM To: Christopher Bartolomucci; christopher.hall@usdoj.gov Cc: TBorelli@lambdalegal.org Subject: Golinski: proposed summary judgment schedule Chris and Chris, We wanted to touch base with you about the proposed summary judgment schedule attached to BLAG's summary judgment opposition brief. We don't think any further discovery has been shown to be necessary. To allow things to move forward quickly if the Court disagrees, however, we wanted to meet and confer with you regarding the schedule BLAG proposed. If the Court believes additional discovery to be necessary, we would be amenable to the schedule proposed, with the revisions reflected in the attached proposed order. As you can imagine, we will want to re-file our motion for summary judgment to account for what happens in discovery. To accommodate that, we have suggested some modification of the expert deadlines and the close of discovery. We also added a stipulation regarding the depositions of the experts. Please let me know if you are agreeable to our revisions. We would like to be able to represent your position to the Court in our filing on Friday. Best, Rita Rita Lin | Morrison & Foerster LLP 425 Market Street | San Francisco, California 94105 Tel. (415) 268-7466 | Fax (415) 268-7522 --------------------------------------------------------------------To ensure compliance with requirements imposed by the IRS, Morrison & Foerster LLP informs you that, if any advice concerning one or more U.S. Federal tax issues is contained in this communication (including any attachments), such advice is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. For information about this legend, go to http://www.mofo.com/Circular230/ ============================================================================ This message contains information which may be confidential and privileged. Unless you are the addressee (or authorized to receive for the addressee), you may not use, copy or disclose to anyone the message or any information contained in the message. If you have received the message in error, please advise the sender by reply e-mail @mofo.com, and delete the message. ---------------------------------------------------------------------

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