Fannie Mae (FNMA)

[Patswil]

t appears that the document phase of discovery is nearing completion.
Now, however, the Government seeks once again to bring this case to a halt, this time
pending resolution of the appeals from the district court’s decision in Perry. But just as there
was no legitimate basis to stay this case at its outset pending the resolution of actions challenging
the Net Worth Sweep in the D.D.C., there is no “pressing need” to stay this case now pending
resolution of the appeals from the D.D.C.’s judgment dismissing challenges to the Net Worth
Sweep. The Government has not carried its heavy burden to justify a stay, and its motion should
be denied.
https://timhoward717.files.wordpress.com/2014/12/121814-redacted-response-in-opposition-to-defendant_s-motion-to-stay-all-proceedings-2.pdf

QUESTIONS PRESENTED
1. Whether the Government has demonstrated (a) a pressing need for an indefinite
stay of all proceedings in this action, and (b) that the balance of interests weighs in favor of such
Case 1:13-cv-00465-MMS Document 118-1 Filed 12/18/14 Page 5 of 392
a stay.