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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
NAVY SEALs 1-3, et al.,
Plaintiffs,
v.
LLOYD J. AUSTIN, III in his official capacity as
United States Secretary of Defense, et al.,
Defendants.
Case No. 4:21-cv-01236-O
DEFENDANTS’ MOTION TO COMPEL PLAINTIFFS TO
ANSWER DEFENDANTS’ REQUESTS FOR ADMISSIONS
Pursuant to Federal Rule of Civil Procedure 36(a)(6), Defendants respectfully request that this
Court order Plaintiffs to answer Defendants’ First Set of Requests for Admissions fully and
completely, in accordance with the proposed order and for the reasons set forth in the accompanying
memorandum and supporting materials.
Dated: October 14, 2022
Respectfully submitted,
BRIAN M. BOYNTON
Principal Deputy Assistant Attorney General
ALEXANDER K. HAAS
Director, Federal Programs Branch
ANTHONY J. COPPOLINO
Deputy Director
/s/ Jody D. Lowenstein
ANDREW E. CARMICHAEL
AMY E. POWELL
Senior Trial Counsel
STUART J. ROBINSON
Senior Counsel
CODY T. KNAPP (NY #5715438)
JODY D. LOWENSTEIN (MT #55816869)
ZACHARY A. AVALLONE
LIAM C. HOLLAND
Case 4:21-cv-01236-O Document 203 Filed 10/14/22 Page 1 of 3 PageID 6827
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Trial Attorneys
United States Department of Justice
Civil Division, Federal Programs Branch
1100 L Street NW
Washington, DC 20005
Phone: (202) 598-9280
Email: jody.d.lowenstein@usdoj.gov
Counsel for Defendants
Case 4:21-cv-01236-O Document 203 Filed 10/14/22 Page 2 of 3 PageID 6828
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CERTIFICATE OF CONFERENCE
Defendants’ counsel conferred with Plaintiffs’ counsel regarding this motion by email and
telephone on multiple occasions between September 8 and October 3, 2022. Plaintiffs indicated that
they oppose the relief requested in Defendants’ motion.
/s/ Jody D. Lowenstein
JODY D. LOWENSTEIN
Trial Attorney
United States Department of Justice
Civil Division, Federal Programs Branch
Case 4:21-cv-01236-O Document 203 Filed 10/14/22 Page 3 of 3 PageID 6829