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Case 3:17-cv-02692-S Document 13 Filed 01/30/18 Page 1 of 2 PageID 224

UNITED STATES DISTRICT COURT


NORTHERN DISTRICT OF TEXAS

BRUCE JOINER, )
)
Plaintiff, )
)
v. )
) Case No. 3:17-cv-02692
UNITED STATES OF AMERICA, )
)
Defendant. )
____________________________________)

DEFENDANT UNITED STATES OF AMERICA’S MOTION FOR RELIEF FROM


ORDER REQUIRING A SCHEDULING CONFERENCE AND REPORT
AND FOR A STAY OF DISCOVERY

Defendant United States of America respectfully moves this Court to relieve the parties

from the reporting requirements set forth in the Court’s order dated January 16, 2018 (Dkt. # 12),

to abstain from entering a scheduling order, and for a stay of discovery while the United States’

motion to dismiss (Dkt. ## 8, 9, 10) is pending. The grounds for the relief sought in this motion

are set forth in the accompanying memorandum in support.

Dated: January 30, 2018 Respectfully submitted,

CHAD READLER
Acting Assistant Attorney General

JAMES G. TOUHEY, JR.


Director, Torts Branch
Civil Division

RUPERT M. MITSCH
Assistant Director, Torts Branch
Civil Division

United States’ Motion for Relief From Order Requiring Scheduling Report and for Stay of Discovery- 1
Case 3:17-cv-02692-S Document 13 Filed 01/30/18 Page 2 of 2 PageID 225

/s/ Phil MacWilliams


PHILIP D. MACWILLIAMS
Trial Attorney
E-mail: phil.macwilliams@usdoj.gov
U.S. Department of Justice
Civil Division, Torts Branch
1331 Pennsylvania Ave., NW
Room 8080N
Washington, DC 20004
Telephone: (202) 616-4285
Facsimile: (202) 616-5200

Attorneys for the United States of America

CERTIFICATE OF CONFERENCE

In accordance with Local Rule 7.1, the undersigned conferred with counsel for Plaintiff

on January 26, 2018, who opposes the relief sought in this motion.

/s/ Phil MacWilliams


PHILIP D. MACWILLIAMS

CERTIFICATE OF SERVICE

I hereby certify that on January 30, 2018, I caused to be served upon the following

counsel a true and correct copy of the United States’ Motion For Relief From Scheduling Report

and For A Stay of Discovery and the accompanying memorandum in support via ECF filing:
Trenton Roberts
Roberts & Willie, PLLC
2000 S. Dairy Ashford, Suite 390
Houston, Texas 77077
Phone: (832) 328-7345
Email: trenton@robertsandwillie.com
Attorney for Plaintiff
/s/ Phil MacWilliams
PHILIP D. MACWILLIAMS

United States’ Motion for Relief From Order Requiring Scheduling Report and for Stay of Discovery- 2

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