Gohmert et al v. Pence

Filing 23

Unopposed MOTION for Leave to File Excess Pages for Plaintiffs' Response to Defendants' and Intervenors' Briefs In Opposition by Louie Gohmert, Jake Hoffman. (Attachments: # 1 Text of Proposed Order Proposed Order)(Sessions, William)

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRCT OF TEXAS TYLER DIVISION LOUIS GOHMERT, TYLER BOWYER, NANCY COTTLE, JAKE HOFFMAN, ANTHONY KERN, JAMES R. LAMON, SAM MOORHEAD, ROBERT MONTGOMERY, LORAINE PELLLEGRINO, GREG SAFSTEN, KELLI WARD and MICHAEL WARD, Civil Action No. 6:20-cv-00660-JDK Plaintiffs, (ELECTION MATTER) v. THE HONORABLE MICHAEL R. PENCE, VICE PRESIDENT OF THE UNITED STATES, in his official capacity. Defendant. PLAINTIFFS' UNOPPOSED MOTION TO EXCEED PAGE LIMITS FOR PLAINTIFFS' RESPONSE DEFENDANT'S AND INTERVENORS' BRIEFS IN OPPOSITION Come now the Plaintiffs, U.S. Rep. Louie Gohmert (TX-I), Tyler Bowyer, Nancy Cottle, Jake Hoffman, Anthony Kern, James R. Lamon, Sam Moorhead, Robert Montgomery, Loraine Pellegrino, Greg Safsten, Kelli Ward, and Michael Ward, by and through their undersigned counsel. Plaintiffs request that this Court allow Plaintiffs to file a brief in response to the briefs to be filed by the Defendant and any Intervenors and amicus curiae briefs in opposition to Plaintiffs' Emergency Motion for Expedited Declaratory Judgment and Emergency Injunctive Relief that exceeds the 10-page limit established by L.R. CV-7.l(a)(l) for good cause shown in light of the important nature of this elections case and the constitutional issues raised therein. In support thereof, Plaintiffs state: Case No. 6:20-cv-00660- JDK - Unopposed Motion to Exceed Page Limits for Plaintiffs Reply Brief 1 1. Defendant's and Intervenors' responses, motions and briefs are 64 pages in length. 2. The legal issues raised in the Defendant's, Intervenors, and Amicus Curiae responses are numerous and distinct and require the discussion of multiple factors, along with an application of the complex Constitutional, substantive, and procedural law to the undisputed facts in this case. Plaintiffs require additional pages to adequately respond to these arguments. 3. Plaintiffs request permission to file a brief of fifty (50) pages. WHEREFORE, due to the important nature of this case and the legal questions presented, Plaintiffs' request to extend the page length to fifty (50) pages is warranted and reasonable in this case. Dated: December 31, 2020 Howard Kleinhendler Howard Kleinhendler Esquire NY Bar No. 2657120 369 Lexington Ave., 12th Floor New York, New York 10017 Tel: (917) 793-1188 Fax: (732) 901-0832 Email: howard@kleinhendler.com Lawrence J. Joseph DC Bar No. 464777 Law Office of Lawrence J. Joseph 1250 Connecticut Ave, NW, Suite 700-IA Washington, DC 20036 Tel: (202) 355-9452 Fax: 202) 318-2254 Email : lj oseph@larryjoseph.com Respectfully submitted, ~ !,~.___ ::' William Lewis Sessions Texas Bar No . 18041500 Sessions & Associates, PLLC 14591 North Dallas Parkway, Suite 400 Dallas, TX 75254 Tel: (214) 217-8855 Fax: (214) 723-5346 Email: lsessions@sessionslaw.net Julia Z. Haller DC Bar No. 466921 Brandon Johnson DC Bar No. 491370 Defending the Republic 601 Pennsylvania Ave., NW Suite 900 South Building Washington, DC 20004 Tel: (561) 888-3166 Fax: (202) 888-2162 Email: halle1j ulia@outlook.com Email: brandoncjohnson6@aol.com COUNSEL FOR PLAINTIFFS Case No . 6:20 -cv-00660- JDK - Motion to Exceed Page Limits for Plaintiffs Reply Brief 2 CERTIFICATE OF CONFERENCE I certify that as counsel for Plaintiffs, I have complied with the meet and confer requirement in Local Rule CV-7(h) in the following respects: I have personally contacted and spoken with Mr. Jolm Coghlan, Deputy Assistant Attorney General from the Civil Division of the United States Department of Justice in Washington, D.C. whom I understand has authority to respond for Defendant Pence. Mr. Coghlan and I briefly discussed the substance of Plaintiffs' request and was told that Defendant does not oppose the motion. Dated: December 31, 2020 ~ t~~.~,,___ . _ William Lewis Sessions Counsel for Plaintiffs Case No. 6:20-cv-00660- JDK - Motion to Exceed Page Limits for Plaintiffs Reply Brief 3 CERTIFICATE OF SERVICE I certify that on the date specified below, I electronically filed the foregoing motion (together with its accompanying proposed order) with the Clerk of the Comi using the CM/ECF system and caused persons who have appeared of record and the following persons to be served by electronic mail as follows: Gregory F. Jacob Counsel to the Vice President Office of the Vice President Eisenhower Executive Office Building Washington, DC 20501 E-mail: gregory.f.jacob@ovp.eop.gov Stephen J. Cox United States Attorney 350 Magnolia Ave., Suite 150 Beaumont, Texas 77701 E-mail: stephen. j .cox@usdoj.gov Christopher Healy U.S. Department of Justice, Civil Division, Federal Programs Branch 1100 L St. NW I Washington, DC 20005 E-mail: Christopher.Healy@usdoj.gov Douglas N. Letter General Counsel Office of General Counsel U.S. House of Representatives 219 Cannon House Office Building Washington, DC 20515 E-mail: Douglas.Letter@mail.house.gov Alan Hamilton Kennedy 1975 N Grant St Unit 421, Denver, CO 80203 Email: alan.kennedy@aya.yale.edu Dated: December 31, 2020 William Lewis Sessions Counsel for Plaintiffs Case No. 6:20-cv-00660- JDK - Unopposed Motion to Exceed Page Limits for Plaintiffs Reply Brief 4

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