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

Filing 24

Consent MOTION for Extension of Time to Confer and to File Joint Meet and Confer Statement by JEFFERSON B. SESSIONS, UNITED STATES OF AMERICA (Attachments: # 1 Text of Proposed Order)(Cohen, Jason)

Case 1:18-cv-01552-RJL Document 24 Filed 08/14/18 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’ CONSENT MOTION FOR EXTENSION OF TIME FOR PARTIES TO
CONFER AND TO FILE JOINT MEET AND CONFER STATEMENT
Defendants, by and through undersigned counsel, move pursuant to Federal Rule of Civil
Procedure 6(b)(1) for an enlargement of time for the parties to comply with the meet and confer
requirements set forth in the Court’s Case Management Order until 30 days after the Court rules
on the pending motions. As grounds for this motion, Defendants state as follows:
1.

On July 20, 2018, the Court issued its Case Management Order. ECF No. 18. The

Order states that where, as here, a Rule 12(b) motion has already been filed, the parties are to
confer within 30 days of the Order, i.e., by August 20, 2018, and submit a Joint Meet and Confer
Statement fourteen days following the meeting, i.e., by September 4, 2018.
2.

Currently before the Court are two fully briefed motions: Plaintiffs’ Motion for

Preliminary Injunction (ECF No. 5) and Defendants’ Motion to Dismiss (ECF No. 16). Because
Defendants’ Motion is potentially dispositive and Plaintiffs’ Motion may affect the parties’
litigation positions and the management of the case going forward, it is in the interests of judicial

Case 1:18-cv-01552-RJL Document 24 Filed 08/14/18 Page 2 of 2

and party efficiency and economy to extend the meet and confer deadlines while both motions
are pending.
3.

Discovery is not needed to oppose the pending motions and neither party would

be prejudiced by a stay of the meet and confer requirements until the pending motions are
resolved. See, e.g., Labson v. 2200 M Street LLC, No. 03-cv-207 (RJL), 2003 WL 24251643
(D.D.C. Sept. 29, 2003).
4.

The parties conferred and Plaintiff consented to the requested relief.

5.

A proposed order is attached.

Dated: August 14, 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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