Case 1:09-cv-01356-EGS Document 10 Filed 08/07/2009 Page 1 of 2

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

____________________________________
CITIZENS FOR RESPONSIBILITY AND :
ETHICS IN WASHINGTON :
:
Plaintiff, :
:
v. : Civil Action No. 09-1356 (EGS)
:
U.S. DEPARTMENT OF HOMELAND :
SECURITY :
:
Defendant. :
____________________________________:

JOINT MOTION TO STAY PLAINTIFF’S MOTION

FOR A PRELIMINARY INJUNCTION AND DEFENDANT’S OBLIGATION
TO RESPOND TO THE FIRST AMENDED COMPLAINT
AND SUPPORTING MEMORANDUM

Plaintiff Citizens for Responsibility and Ethics in Washington and defendant U.S.

Department of Homeland Security respectfully move the Court to stay further consideration of

plaintiff’s pending motion for a preliminary injunction, including further briefing and the oral

argument scheduled for August 19, 2009, as well as defendant’s obligation to respond to the first

amended complaint. The parties seek this stay in light of the good faith efforts the White House

and the plaintiff have made to resolve the issues in this case. A stay of the pending motion and

defendant’s obligation to respond to the amended complaint will allow the parties to continue

this process.

The parties respectfully suggest that they file a joint status report within 30 days updating

the Court on the status of their efforts.

August 7, 2009 Respectfully submitted,

____/s/_________________
Anne L. Weismann
Case 1:09-cv-01356-EGS Document 10 Filed 08/07/2009 Page 2 of 2

(D.C. Bar No. 298190)

Melanie Sloan
(D.C. Bar No. 434584)
Citizens for Responsibility and Ethics
in Washington
1400 Eye Street, N.W., Suite 450
Washington, D. C. 20005
Telephone: 202-408-5565
Fax: 202-588-5020

Attorneys for Plaintiff

TONY WEST
Assistant Attorney General

JOHN R. TYLER (DC Bar No. 297713)

Assistant Branch Director

/s/ Brad P. Rosenberg

Brad P. Rosenberg (DC Bar No. 467513)
Trial Attorney
United States Department of Justice
Civil Division, Federal Programs Branch
Tel: (202) 514-3374
Fax: (202) 616-8460
brad.rosenberg@usdoj.gov

Mailing Address:
Post Office Box 883
Washington, D.C. 20044

Courier Address:
20 Massachusetts Ave., N.W.
Washington, D.C. 20001

COUNSEL FOR DEFENDANT

U.S. DEPARTMENT OF
HOMELAND SECURITY

2
 Case 1:09-cv-01356-EGS Document 10-2 Filed 08/07/2009 Page 1 of 1

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

____________________________________
CITIZENS FOR RESPONSIBILITY AND :
ETHICS IN WASHINGTON :
:
Plaintiff, :
:
v. : Civil Action No. 09-1356 (EGS)
:
U.S. DEPARTMENT OF HOMELAND :
SECURITY :
:
Defendant. :
____________________________________:

[PROPOSED] ORDER

Upon consideration of the joint motion to stay plaintiff’s motion for a preliminary

inunction and defendant’s obligation to respond to the first amended complaint and the entire

record herein, it is hereby

ORDERED that the motion is granted, further briefing and oral argument on plaintiff’s

motion for a preliminary injunction is hereby stayed, and defendant’s obligation to respond to

the first amended complaint is also hereby stayed, and it is further

ORDERED that the parties are directed to file a joint status report with the Court on or

before September 8, 2009, updating the Court on the status of their efforts to reach a resolution

of this case.

______________________ ________________________________
Date EMMET G. SULLIVAN
United States District Judge