CHAMBER OF COMMERCE OF THE UNITED STATES OF AMERICA v. SERVIN et al

Filing 19

MOTION to Modify Briefing Schedule by CHAMBER OF COMMERCE OF THE UNITED STATES OF AMERICA, MORGAN GOODWIN, JOHN and JANE DOES NOS. 1-20, SARAH MURPHY, PUBLIC CITIZEN, JACQUES SERVIN, DAVID SIEVERS, SUPPORT AND COMMITMENT, INC., IGOR VAMOS. (Attachments: # 1 Text of Proposed Order)(znmw, )

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
CHAMBER OF COMMERCE OF THE
UNITED STATES OF AMERICA,
Plaintiff,
v.
JACQUES SERVIN, et al.
Defendants.

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Case No. 09-CV-02014-RWR

JOINT MOTION TO MODIFY THE BRIEFING SCHEDULE
Defendants filed their motion to dismiss on January 5, 2010. Unless modified,
Plaintiff’s deadline to respond would be January 22, 2010. Public Citizen, a national nonprofit advocacy organization, has sought the parties’ consent to file a memorandum as
amicus curiae in support of Defendants. All parties consent to Public Citizen’s request.
Accordingly, the parties and amicus are jointly filing this motion to propose the following
briefing schedule:
Filing

Proposed Deadline

Public Citizen’s amicus memorandum

January 19, 2010

Plaintiff Chamber of Commerce’s opposition

February 5, 2010

Defendants’ reply

February 15, 2010

Under this schedule, the Plaintiff will be able to respond to both the Defendant’s
and Public Citizen’s memoranda, and will have the same amount of time for its response
as provided under this Court’s Local Rules (14 days plus 3 days for service). Moreover,
the proposed schedule will permit Plaintiff to file a single responsive brief rather than two
different briefs.

Pursuant to Local Civil Rule 7(m), counsel for Public Citizen has discussed this
motion with counsel for all parties. All parties consent to this motion.
Respectfully submitted,
/s/ Robert Corn-Revere
Robert Corn-Revere (DC Bar No. 375415)
DAVIS WRIGHT TREMAINE LLP
1919 Pennsylvania Avenue, NW
Suite 200
Washington, DC 20006
Tel. [phone]
Fax: [phone]
Email: [e-mail]
Counsel for Defendants
/s/ Michael John Mueller
Michael John Mueller (DC Bar No. 424775)
HUNTON & WILLIAMS LLP
1900 K Street, NW, Suite 1200
Washington, DC 20006
Tel. [phone]
Fax. [phone]
Email: [e-mail]
Counsel for Plaintiffs
/s/ Deepak Gupta
/s/ Gregory A. Beck
Deepak Gupta (DC Bar # 495451)
Gregory A. Beck (DC Bar # 494479)
PUBLIC CITIZEN LITIGATION GROUP
1600 20th Street NW
Washington, DC 20009
202-588-1000
Email: [e-mail]
[e-mail]
Counsel for Amicus Curiae Public Citizen
Dated: January 14, 2010