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Filing Summary The filing has been successfully received by CaseFileXpress. Below are the details.
Trace Number:
ED301J000441669
Case Number:
2015 CA 002442 B
Document Type:
Motion Filed:
Lead Document:
MottoExpediteMotiontoStay.pdf
Filer Name:
William Pittard
Attorney0fRecord Name:
William Pittard
Plaintiffs: Plaintiffs Attorneys: Defendants: Defendants Attorneys: Judges:
William Pittard, Peter Maier Judge Bartnoff, Judge Ross
Court Reporters: Others: Total fees:
$0,00
https://dc.casefilexpress.com/SubmitFiling/ConfirmAndSubmit.aspx
10/27/2015
IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
MONTGOMERY BLAIR SIBLEY, Plaintiff, v. THE HONORABLE MITCH MCCONNELL et al., Defendants.
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Case No. 2015 CA 002442 B Hon. Maurice A. Ross
MOTION TO EXPEDITE CONSIDERATION OF OPPOSED MOTION TO STAY, IN PART, OF DEFENDANT THE HONORABLE JOHN A. BOEHNER Pursuant to D.C. Superior Court Rule of Civil Procedure 7(b), Defendant the Honorable John A. Boehner, Speaker of the United States House of Representatives, by and through undersigned counsel, hereby moves for expedited consideration of his contemporaneously-filed Opposed Motion to Stay, in Part (“Motion to Stay”). Speaker Boehner respectfully requests that this Court decide the Motion to Stay by this Friday, October 30, 2015, including by requiring the filing of any responses to that motion by Thursday, October 29, 2015, because Speaker Boehner’s time to respond to the Amended Complaint of Plaintiff Montgomery Blair Sibley arguably otherwise will expire on Monday, November 2, 2015. See Am. Compl. (Oct. 19, 2015; allegedly served Oct. 15, 2015); D.C. Super. Ct. Rules 5, 6, & 15 (rules re: response time). The undersigned contacted Mr. Sibley and co-defendant the Honorable Mitch McConnell, Majority Leader of the United States Senate, late today to ascertain their positions on this motion to expedite. The undersigned did not receive a response from Mr. Sibley.
Majority Leader McConnell stated, through counsel, that he did not expect to be able to provide his position today. A proposed order is attached, and oral argument is not requested. Respectfully submitted, KERRY W. KIRCHER (D.C. Bar No. 386816) General Counsel /s/ William Pittard WILLIAM PITTARD (D.C. Bar No. 482949) Deputy General Counsel SARAH CLOUSE (MA Bar No. 688187) Senior Staff Attorney OFFICE OF GENERAL COUNSEL1 U.S. HOUSE OF REPRESENTATIVES 219 Cannon House Office Building Washington, D.C. 20515 (202) 225-9700 (telephone) (202) 226-1360 (facsimile)
[email protected] Counsel for Defendant the Honorable John A. Boehner, Speaker of the United States House of Representatives October 27, 2015
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Attorneys in the Office of General Counsel for the U.S. House of Representatives are “entitled, for the purpose of performing the counsel’s functions, to enter an appearance in any proceeding before any court of the United States or of any State or political subdivision thereof without compliance with any requirements for admission to practice before such court.” 2 U.S.C. § 5571(a)
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CERTIFICATE OF SERVICE I certify that on October 27, 2015, I electronically filed the foregoing Motion to Expedite Consideration of Opposed Motion to Stay, in Part, of Defendant the Honorable John A. Boehner via the CaseFileXpress system of the Superior Court of the District of Columbia, which I understand caused service on all registered parties. I further certify that I served one copy by first-class mail (postage prepaid) and electronic mail, on: Montgomery Blair Sibley, Esquire 402 King Farm Boulevard, Suite 125-145 Rockville, Maryland 20850
[email protected] Plaintiff, pro se Peter Maier, Special Assistant U.S. Attorney 555 Fourth Street, Northwest Washington, D.C. 20530
[email protected] Counsel for Defendant the Honorable Mitch McConnell
/s/ William Pittard William Pittard
IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
MONTGOMERY BLAIR SIBLEY, Plaintiff, v. THE HONORABLE MITCH MCCONNELL et al., Defendants.
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Case No. 2015 CA 002442 B Hon. Maurice A. Ross
[PROPOSED] ORDER UPON CONSIDERATION OF the Motion to Expedite Consideration of Opposed Motion to Stay, in Part, of Defendant the Honorable John A. Boehner (“Motion”), the memorandum of points and authorities in support thereof, the response(s) thereto, if any, and the entire record herein, it is by the Court this _______ day of _____________________, 2015 ORDERED That the Motion is GRANTED for all the reasons set forth in the memorandum of points and authorities in support; it is further ORDERED That the parties shall file any responses to the Motion to Stay, in Part, of Defendant the Honorable John A. Boehner on or before Thursday, October 29, 2015.
____________________________________ HONORABLE MAURICE A. ROSS Associate Judge
Copies to: Montgomery Blair Sibley, Esquire 402 King Farm Boulevard, Suite 125-145 Rockville, Maryland 20850
[email protected] Plaintiff, pro se Peter Maier, Special Assistant U.S. Attorney 555 Fourth Street, Northwest Washington, D.C. 20530
[email protected] Counsel for Defendant the Honorable Mitch McConnell Kerry W. Kircher, General Counsel William Pittard, Deputy General Counsel Sarah Clouse, Senior Staff Attorney 219 Cannon House Office Building Washington, D.C. 20515
[email protected] [email protected] [email protected] Counsel for Defendant the Honorable John A. Boehner
