The United States is correct that if it moved for summary judgment and if Plaintiff had not requested a stay to conduct discovery, Plaintiff would have to advance arguments and evidence as to why Ms. Thietje was not acting within the scope of her employment in the response. See Lagarde v. U.S., 2010 WL 3310228 (C.D. Ill. Aug. 19, 2010) (holding that a plaintiff bears the burden of persuading the court that the Defendant was not acting in the scope of his employment on a fully briefed motion to dismiss). But here, Plaintiff has moved for a stay to pursue limited discovery on the issue of whether Ms. Thietje was acting within the scope of her employment, which Plaintiff says he needs to respond to the motion for summary judgment predicated on exhaustion.