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`Case 4:21-cv-00595-O Document 49 Filed 06/29/21 Page 1 of 3 PageID 1305Case 4:21-cv-00595-O Document 49 Filed 06/29/21 Page 1 of 3 PageID 1305
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF TEXAS
`FORT WORTH DIVISION
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`SID MILLER, et al.,
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`v.
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`TOM VILSACK, in his official capacity as
`SECRETARY OF AGRICULTURE,
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`Plaintiffs,
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`Defendant.
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`Civil Action No. 4:21-cv-595-O
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`DEFENDANT’S PARTIAL MOTION TO DISMISS
`Pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), Defendants hereby
`move this Court to dismiss in part Plaintiffs’ Amended Complaint. In accordance with Local Rules
`7.1 and 7.2, this motion is accompanied by a brief that sets forth the contentions of law, arguments
`and authorities on which Defendants rely in support of this motion. A proposed order also
`accompanies this motion.
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`1
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`Case 4:21-cv-00595-O Document 49 Filed 06/29/21 Page 2 of 3 PageID 1306Case 4:21-cv-00595-O Document 49 Filed 06/29/21 Page 2 of 3 PageID 1306
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`Dated: June 29, 2021
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`Respectfully submitted,
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`BRIAN M. BOYNTON
`Acting Assistant Attorney General
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`LESLEY FARBY
`Assistant Branch Director
`Civil Division, Federal Programs Branch
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`/s/ Michael F. Knapp
`EMILY SUE NEWTON (VA Bar No. 80745)
`Senior Trial Counsel
`KYLA M. SNOW (Ohio Bar No. 96662)
`MICHAEL F. KNAPP (Cal. Bar. No. 314104)
`Trial Attorneys
`United States Department of Justice
`Civil Division, Federal Programs Branch
`1100 L Street, NW
`Washington, D.C. 20005
`Tel: (202) 514-2071 / Fax: (202) 616-8460
`michael.f.knapp@usdoj.gov
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`Counsel for Defendant
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`2
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`Case 4:21-cv-00595-O Document 49 Filed 06/29/21 Page 3 of 3 PageID 1307Case 4:21-cv-00595-O Document 49 Filed 06/29/21 Page 3 of 3 PageID 1307
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`CERTIFICATE OF SERVICE
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`I hereby certify that on June 29, 2021, a copy of the foregoing was filed electronically via
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`the Court’s ECF system, which effects service upon counsel of record.
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`/s/ Michael F. Knapp
`MICHAEL F. KNAPP (Cal. Bar No. 314104)
`Trial Attorney, U.S. Department of Justice
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