Motion To Expedite - 1: ARDAMICA, et al., v. BRIAN VANCE as Manager of the

Summary

A motion to expedite filed December 8, 2021 as ECF No. 37 in Ardamica, et al. v. Brian Vance, as Manager of the United States Department of Energy Hanford Site, No. 4:21-CV-05148-TOR, in the U.S. District Court for the Eastern District of Washington. The federal defendants, President Joseph R. Biden and Brian Vance, move through United States Attorney Vanessa R. Waldref and Assistant U.S. Attorneys John T. Drake and Molly M.S. Smith. They ask for expedited consideration of their Unopposed Motion for Leave to File Excess Pages (ECF No. 36) because the brief needing extra pages is due December 10, 2021. The caption's plaintiffs include Hanford Security Police Officers and a Department of Energy employee; its defendants include Bechtel and officers of several companies. The three-page filing ends with a certificate of service listing counsel served via CM/ECF.

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“Motion To Expedite - 1: ARDAMICA, et al., v. BRIAN VANCE as Manager of the.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/4-21-cv-05148-recap-gov-uscourts-waed-97667-37-0-fe7cef8ac7/, SHA-256 71e446121d5cdd9813adcdb283eb8381c2dec546acd3fa6d6aea2fc8d9c95876.

Full text

      Case 4:21-cv-05148-TOR    ECF No. 37   filed 12/08/21   PageID.271 Page 1 of 3




 1 Vanessa R. Waldref
 2 United States Attorney
   Eastern District of Washington
 3 John T. Drake
 4 Molly M.S. Smith
   Assistant United States Attorneys
 5 Post Office Box 1494
 6 Spokane, WA 99210-1494
   Telephone: (509) 353-2767
 7
 8
                       UNITED STATES DISTRICT COURT
 9                FOR THE EASTERN DISTRICT OF WASHINGTON
10
11   Hanford Security Police Officers
     DAVID G. DONOVAN and                         No. 4:21-CV-05148-TOR
12   CHRISTOPHER J. HALL, United
     States Department of Energy employee
13   STEPHEN C. PERSONS, Safety Bases             MOTION TO EXPEDITE
14   Compliance Officer THOMAS R.
     ARDAMICA, et al.,
15                                                12/10/21
                               Plaintiff,         Without Oral Argument
16                   v.
17
     BRIAN VANCE as Manager of the
18   UNITED STATES DEPARTMENT
     OF ENERGY Hanford Site, VALERIE
19   MCCAIN, as Vit Plant Project
     Director, BECHTEL, SCOTT SAX as
20   President and Project Manager of
21   CENTRAL PLATEAU CLEANUP
     COMPANY, ROBERT WILKINSON
22   as President and Program Manager of
     HANFORD MISSION INTEGRATED
23   SOLUTIONS, LLC., DON HARDY as
24   Manager of HANFORD
     LABORATORIES MANAGEMENT
25   AND INTEGRATION 222-S
     LABORATORY MANAGER, HIRAM
26   SETH WHITMER as President and
     Program Manager, HPM
27   CORPORATION, STEVEN ASHBY
28   as Laboratory Director, PACIFIC

     MOTION TO EXPEDITE - 1

      Case 4:21-cv-05148-TOR     ECF No. 37   filed 12/08/21   PageID.272 Page 2 of 3




     NORTHWEST NATIONAL
 1   LABORATORY, JOHN
 2   ESCHENBERG as President and Chief
     Executive Officer of WASHINGTON
 3   RIVER PROTECTION SOLUTIONS,
     JOSEPH R. BIDEN, President of the
 4   United States of America,
 5                             Defendants.
 6
           Defendants Joseph R. Biden, President of the United States, and Brian Vance,
 7
 8 as Manager of the United States Department of Energy Hanford Site (“Federal
 9 Defendants”), by and through the United States Attorney for the Eastern District of
10
   Washington, Vanessa R. Waldref, and the undersigned Assistant U.S. Attorneys,
11
12 John T. Drake and Molly M.S. Smith, move for expedited consideration of their
13
     Unopposed Motion for Leave to File Excess Pages (ECF No. 36). An expedited
14
     ruling on the motion is needed because the brief for which Federal Defendants are
15
16 seeking leave to exceed the page limit is due this Friday, December 10, 2021.
17
           DATED this 8th day of December, 2021.
18
19                                               Vanessa R. Waldref
                                                 United States Attorney
20
21                                               s/ John T. Drake
                                                 John T. Drake
22                                               Molly M.S. Smith
23                                               Assistant United States Attorneys
                                                 Attorneys for Federal Defendants
24
25
26
27
28
     MOTION TO EXPEDITE - 2

      Case 4:21-cv-05148-TOR      ECF No. 37   filed 12/08/21   PageID.273 Page 3 of 3




                                CERTIFICATE OF SERVICE
 1
 2         I hereby certify that on December 8, 2021, I caused to be delivered via the
 3
     method listed below the document to which this Certificate of Service is attached
 4
     (plus any exhibits and/or attachments) to the following:
 5
 6     NAME & ADDRESS                             Method of Delivery
 7
       Nathan J. Arnold                           ☒CM/ECF System
 8     Arnold & Jacobowitz PLLC                   ☐Electronic Mail
 9     2701 First Avenue, Suite 200               ☐U.S. Mail
       Seattle, WA 98121
10                                                ☐Other: _______________________
       nathan@CAJlawyers.com
11     Simon Peter Serrano                        ☒CM/ECF System
12
       Silent Majority Foundation                 ☐Electronic Mail
       5426 N. Rd. 68, Ste. D, Box 105
                                                  ☐U.S. Mail
13     Pasco, WA 99301
       pete@silentmajorityfoundation.org          ☐Other: _______________________
14     Mark N. Bartlett                           ☒CM/ECF System
15     Arthur A. Simpson                          ☐Electronic Mail
       Sarah Cox
16                                                ☐U.S. Mail
       Davis Wright Tremaine LLP
       920 Fifth Avenue, Suite 3300               ☐Other: _______________________
17
       Seattle, WA 98104-1610
18     markbartlett@dwt.com
19     arthursimpson@dwt.com
       sarahcox@dwt.com
20
       Kevin C. Baumgardner                       ☒CM/ECF System
21     Jeff Bone                                  ☐Electronic Mail
       Corr Cronin LLP
22                                                ☐U.S. Mail
       1001 Fourth Ave., Suite 3900
23     Seattle, WA 98154                          ☐Other: _______________________
       kbaumgardner@corrcronin.com
24
       jbone@corrcronin.com
25
                                                  s/John T. Drake
26                                                John T. Drake
27
28
     MOTION TO EXPEDITE - 3

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