McCain-Palin 2008, Inc. v. Cunningham et al

Filing 45

Consent MOTION Briefing Schedule by UNITED STATES OF AMERICA. (Attachments: # 1 Proposed Order)(Perrin, Robin)

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McCain-Palin 2008, Inc. v. Cunningham et al Doc. 45 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) ) v. ) ) JEAN CUNNINGHAM, et al., ) ) Defendants. ) ) __________________________________________) Case No. 3:08CV709 PLAINTIFF'S CONSENT MOTION FOR BRIEFING SCHEDULE AND BRIEF IN SUPPORT Plaintiff, the United States of America, by counsel, respectfully requests this Court to enter the attached Briefing Schedule for purposes of summary judgment briefing. In support of this motion, Plaintiff states the following: Defendants filed their Motion for Summary Judgment on July 17, 2009. Plaintiff plans to file a Cross-Motion for Summary Judgment along with its opposition to Defendants' Motion for Summary Judgment. Plaintiff and Defendants have conferred and agreed upon the attached briefing schedule. WHEREFORE, Plaintiff respectfully requests that the Court enter the attached agreedupon Briefing Schedule providing that Plaintiff has until August 28, 2009, in which to file an Opposition and Motion for Summary Judgment; Defendants have until September 11, 2009 to file any Opposition and Reply; and Plaintiff has until September 18, 2009 to file any Reply. Dockets.Justia.com Dated: July 21, 2009 Respectfully Submitted, LORETTA KING ACTING ASSISTANT ATTORNEY GENERAL DANA J. BOENTE UNITED STATES ATTORNEY /s/ ROBIN PERRIN Assistant United States Attorney Virginia State Bar No. 65825 Assistant United States Attorney United States Attorney's Office 600 East Main Street, Suite 1800 Richmond, Virginia 23219 Telephone: (804) 819-5400 Facsimile: (804) 819-7417 Email: Robin.Perrin2@usdoj.gov CHRISTOPHER COATES REBECCA J. WERTZ RICHARD DELLHEIM LEMA BASHIR U.S. Department of Justice Attorneys Civil Rights Division Voting Section 950 Pennsylvania Avenue, N.W./NWB Room 7254 Washington, DC 20530 Telephone: (202) 305-1734 Facsimile: (202) 307-3961 CERTIFICATE OF SERVICE I hereby certify that on this 21st day of July, 2009, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system, which will send a notification of such filing (NEF) to the following: Robert A. Dybing rdybing@t-mlaw.com By: /s/ Robin E. Perrin Virginia State Bar No. 65825 Assistant United States Attorney United States Attorney's Office 600 East Main Street, Suite 1800 Richmond, Virginia 23219 Telephone: (804) 819-5400 Facsimile: (804) 819-7417 Email: Robin.Perrin2@usdoj.gov

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