Case 1:18-cv-01336-TSC Document 20 Filed 06/18/19 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

DANIEL A. UMBERT, et al. )

)
Plaintiffs, ) Civ. No.1:18-cv-01336-TSC
)
v. )
)
UNITED STATES OF AMERICA, et al. )
)
Defendants. )
____________________________________)

MOTION FOR RULING ON ECF NO. 12

This matter was filed on June 5, 2018 [ECF 1] and all defendants were

served on June 11, 2018 [ECF 5]. An amended complaint was filed on July

1, 2018 [ECF 6] and all defendants served on July 9, 2018 [ECF 9]. After two

extensions for the defendants to answer were granted, on October 12, 2018,

the defendants moved to dismiss in part, sever the remaining claims and to

stay further response to the amended complaint pending the outcome of their

motion to dismiss and sever [ECF 12]. After another extension request by the

defendants, the motion was fully briefed on November 5, 2018. No decision

on defendants’ motion has been entered.

Due to the length of time that defendants’ motion has been pending and

that Plaintiffs are still no closer to resolution of their claims, Plaintiffs

respectfully request that this Honorable Court rule on defendants’ motion

 Case 1:18-cv-01336-TSC Document 20 Filed 06/18/19 Page 2 of 3

[ECF 12] so that this matter may move forward. Counsel for plaintiffs

requested from defendants’ counsel their position on this motion, and counsel

for defendants stated that they took no position on this motion. Should the

Court desire a status conference or otherwise need additional information,

Plaintiffs are happy to assist however they can. A proposed order is attached.

Dated this, the 18th of June, 2019.

Respectfully Submitted,

/s/ Stephen D. Stamboulieh

Stephen D. Stamboulieh
Stamboulieh Law, PLLC
P.O. Box 4008
Madison, MS 39130
(601) 852-3440
stephen@sdslaw.us
DC District Court Bar# MS0009

Alan Alexander Beck

Law Office of Alan Beck
2692 Harcourt Drive
San Diego, CA 92123
(619) 905-9105
Hawaii Bar No. 9145
Alan.alexander.beck@gmail.com
DC District Court Bar# HI001
Counsel for Plaintiffs

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 Case 1:18-cv-01336-TSC Document 20 Filed 06/18/19 Page 3 of 3

CERTIFICATE OF SERVICE

I, Stephen D. Stamboulieh, counsel for Plaintiffs, hereby certify that on

this day, I have caused to be filed the foregoing document or pleading with
the District Court’s ECF system which sent a notice and a copy of the
foregoing to all counsel of record.

Dated: June 18, 2019

/s/ Stephen D. Stamboulieh

Stephen D. Stamboulieh