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Judicial Watch • Judicial Watch vs. Internal Revenue Service 01559 Pltf’s Notice (7-17-2015) – Filed

Judicial Watch vs. Internal Revenue Service 01559 Pltf’s Notice (7-17-2015) – Filed

Judicial Watch vs. Internal Revenue Service 01559 Pltf’s Notice (7-17-2015) – Filed

Page 1: Judicial Watch vs. Internal Revenue Service 01559 Pltf’s Notice (7-17-2015) – Filed

Category:Legal Document

Number of Pages:2

Date Created:July 17, 2015

Date Uploaded to the Library:July 22, 2015

Tags:Pltfs, productions, updates, Ramona, cotca, 01559, Internal, hearing, notice, Revenue, 2015, order, service, filed, plaintiff, document, district, court, IRS

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Case 1:13-cv-01559-EGS Document Filed 07/17/15 Page THE UNITED STATES DISTRICT COURT
Civil Action No. 13-1559-EGS
Plaintiff Judicial Watch, Inc. Judicial Watch counsel, respectfully submits this
Notice update the Court the agency document production since the July 2015 status
The Court held status conference this matter July 2015. See Minute
Order entered 6/18/15. During the course the hearing, the Court directed the IRS from the
bench begin producing responsive records Judicial Watch weekly basis, well
provide status updates with its productions. 7/10/15 Status Conf. Tr. pp. 14, 16-17 (Ex. 1).
Since the hearing, the IRS has not met its obligations produce records every
week with status reports.
After the hearing, agency counsel asked Judicial Watch email July 2015
whether would consent the previous monthly production schedule, rather than the weekly
productions ordered the Court. See email string with Geoffrey Klimas, Esq. from 7/6/15 7/10/15 (Ex. 2(a)). the spirit cooperation, Judicial Watch represented that would not
oppose motion for reconsideration the IRS for order amend the production schedule
every two weeks from the date the hearing with status updates. Id. response, the IRS
represented that will produce records every two weeks starting July 15, 2015 but that does not
Case 1:13-cv-01559-EGS Document Filed 07/17/15 Page
intend file motion for reconsideration until after the Court enters written minute order from
the hearing. Id.
Since then, the IRS further refuses submit status reports updates with the
documents productions addressed and directed the Court until such time the Court enters
written minute order when the IRS deems that one necessary light future
Ex. pp. 16-17; See email string with Stephanie Sasarak, Esq. from 7/15/15 7/17/15 (Ex. 2(b)). The first document production from the IRS since the July hearing was
received yesterday, July 16, 2015, without status report. Ex. 2(b).
The parties conferred telephone this morning specifically discuss the IRS
obligations under the Court standing order produce status updates with its document
productions, but were not able reach agreement.
Judicial Watch believes appropriate and necessary notify the Court the
actual productions and updates, and lack thereof, which the IRS has made since the hearing.
The parties agree status call with the Court the Court deems that would
appropriate and necessary clarify the IRS obligations until the Court has opportunity
enter written order reflecting its ruling from the bench during the July 2015 status conference.
Dated: June 17, 2015
Respectfully submitted,
/S/ Ramona Cotca
Ramona Cotca, D.C. Bar No. 501159
425 Third Street SW, Suite 800
Washington, 20024
(202) 646-5172
Attorneys for Plaintiff