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SCOTT N. SCHOOLS (SCBN 9990)
United States Attorney
JOANN M. SWANSON (CSBN 88143)
Chief, Civil Division
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: (415) 436-6855
Facsimile: (415) 436-6927
Email: joann.swanson@usdoj.gov
Attorneys for Federal Defendant
Library of Congress Copyright Office
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
LONNELL B. WORTHY,
Plaintiff,
v.
LIBRARY OF CONGRESS COPYRIGHT
OFFICE,
Defendant.
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No. C 07-5736 CRB
FEDERAL DEFENDANT’S REPLY TO
MOTION TO DISMISS
Date: January 4, 2008
Time: 10:00 a.m.
Ctrm: 8, 19th Fl.
The Federal Defendant Library of Congress Copyright Office has specially appeared to
move to dismiss plaintiff’s action without prejudice. It has filed its motion on the grounds that
the Court lacks subject matter jurisdiction over the action and that the complaint fails to state a
claim upon which relief can be granted. Plaintiff has not opposed the motion. The Federal
Defendant requests that the action should be dismissed with leave for plaintiff to file and serve an
amended complaint within 30 days.
Respectfully submitted,
SCOTT N. SCHOOLS
United States Attorney
Dated: December 21, 2007
By:
___/s/______________________
JOANN M. SWANSON
Assistant U.S. Attorney
Chief, Civil Division
Worthy v. Library of Congress Copyright Office
Doc. 12
Dockets.Justia.com
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Defs. Reply To Motion to Dismiss
C 07-5736 CRB
2
CERTIFICATE OF SERVICE
Worthy v. Library of Congress Copyright Office
C 07-5736 CRB
The undersigned hereby certifies that she is an employee of the Office of the United States
Attorney for the Northern District of California and is a person of such age and discretion to be
competent to serve papers. The undersigned furthe