Georgia Latino Alliance for Human Rights et al v. Deal et al

Filing 34

MOTION for Leave to File Excess Pages by Mike Beatty, Nathan Deal, Samuel S. Olens, Clyde L. Reese, III. (Attachments: # 1 Text of Proposed Order)(Orland, Devon)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
GEORGIA LATINO ALLIANCE *
FOR HUMAN RIGHTS, et al.,
*
*
Plaintiffs ,
*
*
V.
*
*
NATHAN DEAL, Governor of the *
State of Georgia, et al.,
*
*
Defendants.

1:11-CV-1804-TWT

MOTION TO EXCEED TWENTY-FIVE PAGE LIMIT
Defendants Nathan Deal; Samuel S. Olens, Clyde L. Reese, III, and Mike
Beatty respectfully request leave to file their Brief in support of their Motion to
Dismiss which exceeds the twenty-five page limit for Briefs under Local Rule 7.1.
Defendants show that it is necessary for Defendants to exceed the usual page limit
in order to fully respond to Plaintiff’s complaint.
Plaintiffs have filed an 80-page, 195-paragraph Complaint, enumerating six
counts on behalf of 21 Plaintiffs.

The Plaintiffs pose a facial constitutional

challenge to a state statue and seek to enjoin its effect. Plaintiffs have filed a Brief
in Support of their Motion for Preliminary Injunction which is 60 pages in length.
In addition to failure to state a claim, Defendants’ brief will address issues of

associational and individual standing and immunity. Defendants believe that the
brief they submit will assist the Court in the resolution of this case, as well as any
motion Plaintiffs file seeking preliminary injunctive relief. Defendants believe that
the additional pages are required to adequately address the issues involved.
For the foregoing reasons, Defendants Nathan Deal; Samuel S. Olens, Clyde
L. Reese, III, and Mike Beatty respectfully request that this Court grant their
Motion to Exceed Twenty-Five Page Limit and allow them to file a brief that is no
longer than 35 pages in length.
This 8th day of June, 2011.
Respectfully submitted,
SAMUEL S. OLENS
Attorney General

551540

KATHLEEN PACIOUS
Deputy Attorney General

558555

/s/ Devon Orland
DEVON ORLAND
554301
Sr. Assistant Attorney General
Please Address All
Communications To:
Devon Orland
40 Capitol Square, S.W.
Atlanta, GA 30334-1300
[phone] / Fax: [phone]

CERTIFICATE OF COMPLIANCE

Pursuant to Local Rule 7.1(D), I hereby certify that the foregoing has been
prepared in compliance with Local Rule 5.1(B) in 14-point New Times Roman
type face.
This the 8th day of June, 2011.

/s/ Devon Orland
DEVON ORLAND
554301
Sr. Assistant Attorney General

40 Capitol Square, S.W.
Atlanta, GA 30334-1300
[phone] (Telephone)
[phone] (Fax)
Email: [e-mail]

CERTIFICATE OF SERVICE
I hereby certify that on this date I electronically filed the foregoing
MOTION TO EXCEED PAGE LIMIT with the Clerk of Court using the
CM/ECF system which will automatically send email notification of such
filing to the following attorneys of record:
[e-mail]
[e-mail]
[e-mail] [e-mail]
[e-mail]
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[e-mail]
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I further certify that I have served, by U.S. mail, first class postage
prepaid, the following non-CM/ECF participants: NONE.
This 8rd day of June, 2011.

s/ Devon Orland
State Law Department
40 Capitol Square SW
Atlanta, GA 30334
Tel: [phone]
Fax: [phone]
Email: [e-mail]