WOODHULL FREEDOM FOUNDATION et al v. UNITED STATES OF AMERICA et al

Filing 20

Unopposed MOTION for Extension of Time to File Response/Reply as to 16 MOTION to Dismiss (Duplicate filing of ECF No. 15) by JEFFERSON B. SESSIONS, UNITED STATES OF AMERICA (Attachments: # 1 Text of Proposed Order)(Cohen, Jason)

Case 1:18-cv-01552-RJL Document 20 Filed 08/02/18 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WOODHULL FREEDOM FOUNDATION,
et al.,

)
)
)
Plaintiffs,
)
)
vs.
)
)
UNITED STATES OF AMERICA and
)
JEFFERSON B. SESSIONS, in his official
)
capacity as ATTORNEY GENERAL OF THE
)
UNITED STATES,
)
)
Defendants.
)
_________________________________________ )

Civil Action No. 18-01552 (RJL)

DEFENDANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
REPLY TO PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS
Defendants, by and through undersigned counsel, move pursuant to Federal Rule of Civil
Procedure 6(b)(1) for an enlargement of time until August 6, 2018, to file their reply to
Plaintiffs’ opposition to Defendants’ motion to dismiss, and as grounds for this motion, state as
follows.
1.

This action for declaratory and injunctive relief challenging the constitutionality

of the Allow States and Victims to Fight Online Sex Trafficking Act of 2017 (“FOSTA”) was
filed by Plaintiffs on June 28, 2018. ECF No. 1. Concurrent with the filing of the Complaint
Plaintiffs filed a Motion for Preliminary Injunction (ECF No. 5) seeking to enjoin any and all
enforcement of FOSTA during the pendency of this case.
2.

On July 12, 2018, Defendants filed a combined opposition to Plaintiffs’ motion

for preliminary injunction and motion to dismiss Plaintiffs’ complaint. ECF No. 15 & 16.
3.

On July 26, 2016, Plaintiffs filed their opposition to the motion to dismiss. ECF

No. 19. Pursuant to Local Civil Rule 7(d), Defendants’ reply is due August 2, 2018.

Case 1:18-cv-01552-RJL Document 20 Filed 08/02/18 Page 2 of 2

4.

The Court held a motion hearing on July 19, 2018, regarding Plaintiffs’ motionf

or preliminary injunction. The docket notes that the parties may file supplemental pleadings
within ten days of their receipt of the transcript of that hearing.
5.

The parties each received a copy of the July 19th hearing transcript on Friday,

July 27, 2018. Accordingly, the parties’ supplemental briefs are due August 6, 2018.
6.

Defendants anticipate significant overlap between the reply and the supplemental

brief and prefer to file a single consolidated brief on August 6, 2018. Pursuant to Local Civil
Rule 7(m), the parties conferred, and Plaintiff has no objection to Defendants’ proposal to
consolidate the pleadings and file on August 6th.
7.

A proposed order is attached.

Dated: August 2, 2018

Respectfully submitted,
JESSIE K. LIU, D.C. Bar #472845
United States Attorney
DANIEL F. VAN HORN, D.C. Bar #924092
Chief, Civil Division
By:

/s/ Jason T. Cohen
JASON T. COHEN, ME Bar #004465
Assistant United States Attorney
Civil Division
555 Fourth St., N.W.
Washington, D.C. 20530
Phone: [phone]
Fax: [phone]
Email: [e-mail]

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