State of Texas v. EEOC et al

Filing 33

Unopposed MOTION for Leave to File Reply Brief in Support of Motion to Dismiss filed by Jacqueline Berrien, EEOC, Eric H Holder with Brief/Memorandum in Support. (Attachments: # 1 Exhibit(s) Proposed Reply Brief) (Sandberg, Justin)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
LUBBOCK DIVISION
STATE OF TEXAS,
Plaintiff,
v.
EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION, et al.,
Defendants

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Civil No. 5:13-CV-00255-C
ECF

UNOPPOSED MOTION TO FOR LEAVE TO FILE REPLY BRIEF
Defendants Equal Employment Opportunity Commission (EEOC), Jacqueline A. Berrien,
Chair of the EEOC, and Eric Holder, U.S. Attorney General, within the time allowed by Local Rule
7.1(f), move the Court for leave to file a reply brief in support of their Motion to Dismiss First
Amended Complaint, April 4, 2014, Dckt. No. 29.

The United States respectfully submits that the

interests of justice and judicial economy will be served by granting it leave to file a reply brief to
address the issues raised in Texas’s response.

A copy of the United States’ proposed reply is

attached hereto as Exhibit 1 for the Court’s consideration.

As reflected by the Certificate of

Conference, Texas does not oppose the motion.

DATED this 2nd Day of May, 2014

Respectfully submitted,
STUART F. DELERY
Assistant Attorney General
SARAH R. SALDAÑA
United States Attorney

Mtn. for Leave to File Reply. - Page 1

JOSHUA E. GARDNER
Assistant Director, Federal Programs
Branch
s/ Justin M. Sandberg
BRIAN G. KENNEDY (D.C. Bar No.
228726)
Senior Trial Counsel
JUSTIN M. SANDBERG (IL Bar No.
6278377)
Trial Attorney
U.S. Department of Justice
Civil Division, Federal Programs Branch
20 Mass. Ave. NW, Rm. 7302
Washington, D.C. 20001
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
Counsel for Defendants

CERTIFICATE OF CONFERENCE
I conferred with counsel for the plaintiff, Andrew Oldham, via electronic mail on May 1, 2014.
Mr. Oldham stated that plaintiff has no objection to the request for leave to file a reply brief.
s/ Justin M. Sandberg
JUSTIN M. SANDBERG
Trial Attorney
U.S. Department of Justice

Mtn. for Leave to File Reply. - Page 2

CERTIFICATE OF SERVICE
I hereby certify that, on May 2, 2014, a true and correct copy of the foregoing and the
attached exhibit was served by CM/ECF on:
Jonathan F. Mitchell
Andrew Stephen Oldham
Arthur D’Andrea
Office of the Texas Attorney General
209 West 14th Street
P.O. Box 12548
Austin, Texas 70711-2548.
s/ Justin M. Sandberg
JUSTIN M. SANDBERG
Trial Attorney
U.S. Department of Justice

Mtn. for Leave to File Reply. - Page 3