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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