Escolar Documentos
Profissional Documentos
Cultura Documentos
BRENNAN M. GILMORE,
Plaintiff,
v.
Defendants.
Elizabeth B. Wydra, admitted pro hac vice Andrew Mendrala, Virginia Bar No. 82424
Brianne J. Gorod, admitted pro hac vice Aderson Francois, admitted pro hac vice
CONSTITUTIONAL ACCOUNTABILITY CIVIL RIGHTS CLINIC
CENTER GEORGETOWN UNIVERSITY LAW CENTER
1200 18th Street, N.W., Suite 501 600 New Jersey Avenue, N.W.
Washington, D.C. 20036 Washington, D.C. 20001
(202) 296-6889 (202) 662-9065
elizabeth@theusconstitution.org andrew.mendrala@georgetown.edu
brianne@theusconstitution.org aderson.francois@georgetown.edu
Words-N-Ideas, LLC filed a motion for sanctions under Federal Rule of Civil Procedure 11(c).
Dkt. Nos. 101, 102. This motion was filed more than seven months after Plaintiff Brennan Gilmore
filed his original complaint, nearly six months after Plaintiff filed his amended complaint, more
than three months after briefing concluded on all Defendants’ motions to dismiss, and roughly
three weeks before this Court is set to hear oral argument on those motions. Plaintiff respectfully
requests that this Court defer consideration of the motion for sanctions, and postpone the deadline
for Plaintiff’s response to that motion, until after the motion-to-dismiss hearing scheduled for No-
A delay is warranted here because Defendants’ motion for sanctions simply rehashes the
same arguments that Defendants already made in their motion to dismiss. Thus, the issues that the
motion raises are the very same issues that have already been briefed in great detail by both De-
fendants and by Plaintiff: whether the court has subject-matter jurisdiction and personal jurisdic-
tion over Defendants, and whether Plaintiff has stated claims for defamation and intentional inflic-
tion of emotional distress against Defendants. There is no reason for the Court to receive even
more briefing on these same issues in the context of a Rule 11 motion. It would be more efficient
for the Court to defer consideration of this motion until after the November 13, 2018 oral argument
on the Defendants’ motion to dismiss, at which point the Court can determine whether further
For those reasons, Plaintiff requests that the Court defer consideration of the motion for
sanctions, and postpone the deadline for Plaintiff’s response to that motion, until after the motion-
As of the time of filing, counsel for Defendants Hoft, Stranahan, Creighton, Wilburn, Hick-
ford, and Words-N-Ideas, LLC has not taken a position on the relief requested in this motion.
1
Case 3:18-cv-00017-NKM-JCH Document 105 Filed 10/24/18 Page 2 of 4 Pageid#: 1583
Respectfully submitted,
Dated October 24, 2018 /s/ Andrew Mendrala
Elizabeth B. Wydra, admitted pro hac vice Andrew Mendrala, Virginia Bar No. 82424
Brianne J. Gorod, admitted pro hac vice Aderson Francois, admitted pro hac vice
CONSTITUTIONAL ACCOUNTABILITY CIVIL RIGHTS CLINIC
CENTER GEORGETOWN UNIVERSITY LAW CENTER
1200 18th Street, N.W., Suite 501 600 New Jersey Avenue, N.W.
Washington, D.C. 20036 Washington, D.C. 20001
(202) 296-6889 (202) 662-9065
elizabeth@theusconstitution.org andrew.mendrala@georgetown.edu
brianne@theusconstitution.org aderson.francois@georgetown.edu
2
Case 3:18-cv-00017-NKM-JCH Document 105 Filed 10/24/18 Page 3 of 4 Pageid#: 1584
CERTIFICATE OF SERVICE
I hereby certify that on October 24, 2018, the foregoing document was filed with the Clerk
of the Court, using the CM/ECF system, causing it to be served on all counsel of record.
3
Case 3:18-cv-00017-NKM-JCH Document 105 Filed 10/24/18 Page 4 of 4 Pageid#: 1585