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Judicial Watch • JW v State 00688

JW v State 00688

JW v State 00688

Page 1: JW v State 00688

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Number of Pages:4

Date Created:January 14, 2016

Date Uploaded to the Library:January 15, 2016

Tags:potentially, 00688, ORDERED, SCHEDULE, files, Civil, motion, documents, responsive, Secretary, defendant, filed, State Department, plaintiff, document, FOIA, department, states, district, united


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Case 1:15-cv-00688-RC Document Filed 01/14/16 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
____________________________________
JUDICIAL WATCH, INC.,
Plaintiff,
U.S. DEPARTMENT STATE,
Defendant.
____________________________________)
Civil Action No. 1:15-cv-00688 (RC)
DEFENDANT MOTION STAY BRIEFING SCHEDULE
Defendant Department State State hereby moves stay the briefing schedule
this case allow conduct searches recently-identified source potentially responsive
documents. support this motion, State, through undersigned counsel, states the following.
State Motion for Summary Judgment currently due January 15, 2016.
Scheduling Minute Order Nov. 2015. State, however, recently identified source
potentially-responsive State Department documents collection electronic files that had
not previously been identified searched. State cannot complete its search these files for
responsive documents before the date set for State motion for summary judgment. search the newly identified documents, State must upload the files system which they can electronically searched, process that currently underway. Because the
uploading not complete, not possible this time estimate the volume potentially
responsive documents, any, that will found. State proposes that first complete the upload the files that they are electronically searchable, and then conduct searches for potentially
responsive documents. State estimates can complete this process and file status report
Case 1:15-cv-00688-RC Document Filed 01/14/16 Page
disclosing the volume potentially responsive documents and proposing revised schedule
February 2016.
This request not for purposes delay, but necessary for State properly
process and produce any responsive records Plaintiff and move for summary judgment.
Granting this extension would allow State complete its production responsive documents
and permit the parties brief summary judgment single, consolidated round.
State, therefore, respectfully moves the Court stay the briefing schedule and set
the following deadlines: (1) later than February 2016, State shall complete its additional
search and file status report disclosing the volume potentially responsive documents that
must reviewed and proposing revised schedule for the production the non-exempt
portions responsive documents subject FOIA; (2) later than February 2016,
Plaintiff shall file response State proposed production schedule.
Another judge this District has already granted similar motion filed State.
See Minute Order (Jan. 12, 2016), Judicial Watch, Inc. U.S. Dep State, No. 1:14-cv01511-ABJ.
Counsel for State has consulted with counsel for Judicial Watch, which has
informed State that does not oppose the relief sought this motion State provides Judicial
Watch advance with the names the current former State Department employees who
created received the documents. The newly identified files that need searched this
case consist office files that were available employees within the Office the Secretary
during former Secretary Clinton tenure well individual files belonging Jake Sullivan
and Cheryl Mills.
Case 1:15-cv-00688-RC Document Filed 01/14/16 Page
Dated: January 14, 2016
Respectfully submitted,
BENJAMIN MIZER
Principal Deputy Assistant Attorney General
ELIZABETH SHAPIRO
Deputy Director
/s/ Daniel Riess
DANIEL RIESS
Trial Attorney
U.S. Department Justice
Civil Division, Federal Programs Branch Massachusetts, Avenue, N.W.
Washington, 20530
Tel: 202-353-3098
daniel.riess@usdoj.gov
Counsel for Defendant
Case 1:15-cv-00688-RC Document 21-1 Filed 01/14/16 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
Plaintiff,
U.S. DEPARTMENT STATE,
Defendant.
Civil Action No. 1:15-cv-00688 (RC)
PROPOSED ORDER
Upon consideration Defendant Motion Stay Briefing Schedule, hereby
ORDERED that the motion GRANTED. further ORDERED that the present summary
judgment briefing schedule stayed, and that:
(1) later than February 2016, Defendant shall complete its additional search and
file status report disclosing the volume potentially responsive documents that must
reviewed and proposing revised schedule for the production the non-exempt portions
responsive documents subject FOIA; and
(2) later than February 2016, Plaintiff shall file response Defendant
proposed production schedule. ORDERED this _____ day _________________, 2016.
________________________________
RUDOLPH CONTRERAS
UNITED STATES DISTRICT JUDGE