From:¶
Subject: Jane Does v. U.S. - Draft Motion to Stay Discovery¶
Date: Sat, 05 Nov 2011 19:37:35 +0000¶
Importance: Normal¶
Attachments: jane_does_Motion_stayDisc.wpd¶
and¶
Attached please find my draft motion to stay discovery. In the factual background section, I review many of the requests, in an attempt to demonstrate how petitioners are overreaching into irrelevant areas. I don’t believe the stay motion needs to be filed under seal, unless expressing the view that a case still exists, in which petitioners can consult with the attorney for the government, is not a matter to be disclosed in a public filing.¶
I reviewed your motion to dismiss and it is excellent. I have no suggestions or revisions.¶
EFTA00204931¶