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Rainey V VA Motion 9 11
Rainey V VA Motion 9 11
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION SCOTT RAINEY, et al., Plaintiffs, Civil Action H-11-1992
JOINT MOTION FOR ENTRY OF CONSENT DECREE Plaintiffs and Defendants jointly move for entry of the Consent Decree attached hereto as Exhibit A. 1. The parties mediated this case on Wednesday, September 7, 2011. Former
Texas Supreme Court Chief Justice Tom Phillips served as mediator. 2. The mediation was successful, resulting in an agreement between the
parties, which is reflected in the attached Consent Decree. 3. The attached Consent Decree completely resolves this case, disposing of
all claims and parties. 4. As evidenced by their signatures, all parties and counsel agree to and
Respectfully submitted, /s/ Jeffrey C. Mateer________ Jeffrey C. Mateer Attorney-in-Charge Texas Bar No. 13185320 Southern District of Texas Bar No. 38345 Hiram S. Sasser III Texas Bar No. 24039157 Erin E. Leu Texas Bar No. 24070138 LIBERTY INSTITUTE 2001 Plano Parkway, Suite 1600 Plano, Texas 75075 Telephone: (972) 941-4444 Fax: (972) 941-4457 Email: jmateer@libertyinstitute.org John D. Walker Texas Bar No. 00794809 39602 Cimarron Way Magnolia, TX 77354 Tel: 281-252-0222 Fax: 281-259-9596 Email: jwalker@jdwlaw.com Counsel for Plaintiffs
JOSE ANGEL MORENO United States Attorney /s/ Daniel Hu_______ Daniel Hu Texas Bar No. 10131415 Southern District of Texas Bar No. 7959 P.O. Box 61129 Houston, Texas 77208 Telephone: (713) 567-9529 Fax: (713) 718-3303 Email: Daniel.Hu@usdoj.gov Counsel for Defendants Joint Motion for Entry of Consent Decree Page 2
CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was electronically served through the Courts CM/ECF system, or otherwise mailed via First Class Mail, on this 22nd day of September, 2011, to the following parties or attorneys of record: Fred T. Hinrichs Daniel Hu U.S. Attorney's Office P.O. Box 61129 Houston, Texas 77208 Counsel for Defendants