Case 3:14-cv-03872-M Document 26 Filed 02/23/15

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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
_____________________________________
JAY AUBREY ISAAC HOLLIS, individually
and as trustee of the Jay Aubrey Isaac Hollis
Revocable Living Trust,

Case No. 3:14-cv-03872-M

Plaintiff,
v.
ERIC H. HOLDER, JR., Attorney General of
the United States, and B. TODD JONES,
Director, Bureau of Alcohol, Tobacco, Firearms
& Explosives,
Defendants.

DEFENDANTS UNOPPOSED MOTION AND BRIEF TO EXTEND THE PAGE LIMIT

APPLICABLE TO DEFENDANTS REPLY
Pursuant to Local Rule 7.2(c), Defendants respectfully move for a thirteen-page
extension of the 10-page limit for the reply brief in support of their motion to dismiss for lack of
jurisdiction and failure to state a claim. In support of their motion, Defendants represent the
following:
1.

With the Courts leave, Defendants filed a 36-page opening memorandum, ECF No. 14.

2.

With the Courts leave, Plaintiff responded in a 40-page memorandum, ECF No. 23.

3.

As explained in Defendants previous motion for leave to extend the page limit, this case
presents several constitutional questions that the parties are addressing, in part, under a
multi-part framework adopted by the Fifth Circuit in Natl Rifle Assn (NRA) v. ATF,
700 F.3d 185, 194 (5th Cir. 2012). Defendants respectfully submit that the Courts

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analysis of these issues will be aided, and the interests of justice served, by a full
treatment of these issues.
4.

Undersigned counsel has conferred with counsel for Plaintiff, who does not oppose the

relief sought in this motion.

Defendants, therefore, respectfully ask this Court to enter an order granting them an extension of
the ordinary page limit.
Dated: February 23, 2015

Respectfully submitted,
JOYCE R. BRANDA
Acting Assistant Attorney General
JOHN R. PARKER
Acting United States Attorney
/s/ Eric J. Soskin
DIANE KELLEHER
Assistant Branch Director
ERIC J. SOSKIN (PA Bar # 200663)
DANIEL RIESS
Trial Attorneys
U.S. Department of Justice
Civil Division, Rm. 7116
20 Massachusetts Avenue, NW
Washington, D.C. 20530
Telephone: (202) 353-30533
Fax: (202) 616-8460
Email: Eric.Soskin@usdoj.gov
Attorneys for Defendants

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CERTIFICATE OF CONFERENCE
Pursuant to Local Rule 7.1(a) and (b), I hereby certify that on February 23, 2015, I
conferred with Counsel for Plaintiff regarding the relief sought in this motion. Counsel indicated
that Plaintiff does not oppose the relief sought in this motion.

/s/ Eric J. Soskin

Eric Soskin

CERTIFICATE OF SERVICE
On February 23, 2015, I electronically submitted the foregoing document with the clerk
of court for the U.S. District Court, Northern District of Texas, using the electronic case filing
system of the court. I hereby certify that I have served all parties electronically or by another
manner authorized by Federal Rule of Civil Procedure 5(b)(2) or the local rules.

/s/ Eric J. Soskin

Eric J. Soskin