Case 1:08-cv-02234-RJL Document 21 Filed 06/09/2009 Page 1 of 3

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

CHRISTOPHER EARL STRUNK,

Plaintiff,

v. Case No. 1:08-CV-02234 (RJL)

U.S. DEPARTMENT OF STATE,

U.S. DEPARTMENT OF HOMELAND
SECURITY,

Defendants.

DEFENDANTS’ MOTION FOR STAY OF DISCOVERY

Defendants hereby respectfully move the Court to stay any and all discovery until the

pending cross-motions to dismiss [Dkt. #16] and for jury proceedings [Dkt. #19] have been

resolved and a scheduling order governing the remaining portions of this action has been

established. The grounds warranting the entry of a stay are set forth in Defendants’ June 8, 2009

consolidated filing [Dkt. #20].1

Dated: June 9, 2009 Respectfully submitted,

TONY WEST
Assistant Attorney General

ELIZABETH J. SHAPIRO (D.C. Bar No. 418925)

Deputy Branch Director

/s/ Brigham J. Bowen

BRIGHAM J. BOWEN (D.C. Bar No. 981555)
Civil Division, U.S. Department of Justice

1
Pursuant to LCvR 7(m), counsel has conferred with Plaintiff is informed that Plaintiff
opposes this motion.
Case 1:08-cv-02234-RJL Document 21 Filed 06/09/2009 Page 2 of 3

Federal Programs Branch

P.O. Box 883, 20 Massachusetts Ave., N.W.
Washington, D.C. 20044
(202) 514-6289
brigham.bowen@usdoj.gov
Counsel for Defendants

2
 Case 1:08-cv-02234-RJL Document 21 Filed 06/09/2009 Page 3 of 3

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 9th day of June, 2009, a true and correct copy of the

foregoing Motion for Stay of Discovery was served upon Plaintiff by first class United States

mail, postage prepaid marked for delivery to:

Christopher E. Strunk
593 Vanderbilt Ave., #281
Brooklyn, NY 11238

/s/ Brigham J. Bowen

Brigham J. Bowen

3
 Case 1:08-cv-02234-RJL Document 21-2 Filed 06/09/2009 Page 1 of 1

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

CHRISTOPHER EARL STRUNK,

Plaintiff,

v. Case No. 1:08-CV-02234 (RJL)

U.S. DEPARTMENT OF STATE,

U.S. DEPARTMENT OF HOMELAND
SECURITY,

Defendants.

[PROPOSED] ORDER
[#__]

Before the Court are (1) Defendants’ Partial Motion to Dismiss Plaintiff’s Amended

Complaint; (2) Plaintiff’s Motion for Quo Warranto Proceedings; and (3) Defendants’ Motion

for a Stay of Discovery. For the reasons set forth in Defendants’ motions, the Court GRANTS

Defendants’ motions and denies Plaintiff’s motion. All claims regarding records concerning or

regarding President Barack H. Obama are hereby DISMISSED WITH PREJUDICE;

Plaintiff’s motion for quo warranto proceedings and other relief is DENIED; and Defendants’

motion for a stay of discovery is GRANTED. No discovery shall take place until further order

of the Court.

SO ORDERED.

___________________________
June __, 2009 RICHARD J. LEON
United States District Judge