Lincoln Memorial University Duncan School of Law v. American Bar Association (TV1)

Filing 66

Joint MOTION to Lift Stay by American Bar Association, Lincoln Memorial University Duncan School of Law. (Attachments: # 1 Text of Proposed Order of Dismissal Pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii))(Watson, Robert)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TENNESSEE
AT KNOXVILLE

LINCOLN MEMORIAL UNIVERSITY
DUNCAN SCHOOL OF LAW,
Plaintiff,
v.
THE AMERICAN BAR ASSOCIATION,
Defendant.

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Case No. 3:11-CV-608

Judge Varlan
Magistrate Judge Shirley

JOINT MOTION TO LIFT STAY
The parties appear by and through counsel and represent to the Court that they are in
agreement that the stay in the above case should be lifted to allow Plaintiff to voluntarily dismiss
its lawsuit. This Court entered the stay on April 2, 2012 [Doc. 56], concluding that the interests
of judicial economy and efficiency would be served by a stay of the litigation until the
conclusion of the administrative process required under Rule 10 of the ABA Standards and Rules
of Procedure for Approval of Law Schools. The Court continued the stay on May 5, 2012 [Doc.
59], and again on July 5, 2012 [Doc. 60]. Plaintiff having now advised Defendant that it is
voluntarily dismissing its Rule 10 proceeding as of this date, the parties agree that the stay
should now be lifted to allow Plaintiff to voluntarily dismiss its lawsuit. An Order of Dismissal
is also filed to be entered upon this Court lifting the stay in this case.
It is therefore respectfully requested that the Court grant the parties’ Joint Motion to Lift
Stay.

RESPECTFULLY submitted this 26th day of October, 2012.
LINCOLN MEMORIAL UNIVERSITY
DUNCAN SCHOOL OF LAW
By: /s/Robert H. Watson, Jr., BPR No. 1702
ROBERT H. WATSON, JR.
WATSON, ROACH, BATSON
ROWELL & LAUDERBACK, P.L.C.
P.O. Box 131
Knoxville, TN 37901-0131
[phone]
MICHAEL L. CIOFFI
BLANK ROME LLP
1700 PNC Center
201 East Fifth Street
Cincinnati, Ohio 45202
[phone]
ATTORNEYS FOR PLAINTIFF

THE AMERICAN BAR ASSOCIATION
By: /s/Anne E. Rea w/permission by Robert H. Watson, Jr.
ANNE E. REA1
SIDLEY AUSTIN, LLP
One Dearborn Street
Chicago, Illinois 60603
[phone]
HOWARD H. VOGEL (BPR No. 001015)
JEFFREY R. THOMPSON (BPR No. 20310)
P. ALEXANDER VOGEL (BPR No. 023944)
O’NEIL, PARKER & WILLIAMSON, PLLC
7610 Gleason Drive, Suite 200
Knoxville, Tennessee 37919
[phone]
PATRICIA J. LARSON1
STEPHANIE GIGGETTS1
AMERICAN BAR ASSOCIATION
321 N. Clark Street
Chicago, Illinois 60654
[phone]
ATTORNEYS FOR DEFENDANT

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Appearing Pro Hac Vice 

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CERTIFICATE OF SERVICE
I hereby certify that on Friday, October 26, 2012, a copy of the foregoing was filed
electronically. Notice of this filing will be sent by operation of the Court’s electronic filing
system to all parties indicated on the electronic filing receipt. All other parties will be served by
certified U.S. mail, return receipt requested. Parties may access this filing through the Court’s
electronic filing system:
Howard H. Vogel
Jeffrey R. Thompson
P. Alexander Vogel
O’NEIL, PARKER & WILLIAMSON, PLLC
7610 Gleason Drive, Suite 200
Knoxville, Tennessee 37919

Michael L. Cioffi
BLANK ROME LLP
1700 PNC Center
201 East Fifth Street
Cincinnati, OH 45202

Patricia J. Larson
Stephanie Ann Giggetts
AMERICAN BAR ASSOCIATION
321 North Clark Street
Chicago, Illinois 60654

Steven J. Horowitz
Michael P. Doss
Linda R. Friedlieb
Anne E. Rea
SIDLEY AUSTIN LLP
One South Dearborn Street
Chicago, Illinois 60603

Dated October 26, 2012.
/s/Robert H. Watson, Jr., BPR No. 1702
ROBERT H. WATSON, JR.
Attorney for Plaintiff
WATSON, ROACH, BATSON,
ROWELL & LAUDERBACK, P.L.C.
Attorneys at Law
P.O. Box 131
Knoxville, Tennessee 37901-0131
[phone]

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