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Judicial Watch • JW v State joint discovery plan 01363

JW v State joint discovery plan 01363

JW v State joint discovery plan 01363

Page 1: JW v State joint discovery plan 01363

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Number of Pages:5

Date Created:April 15, 2016

Date Uploaded to the Library:May 04, 2016

Tags:Plan, proposed, Discovery, Joint, 01363, Civil, order, defendant, filed, State Department, plaintiff, FBI, document, FOIA, department, states, Washington, district, united


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Case 1:13-cv-01363-EGS Document Filed 04/15/16 Page
UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
____________________________________
JUDICIAL WATCH, INC.,
Plaintiff,
Civil Action No. 13-CV-1363 (EGS)
UNITED STATES DEPARTMENT
STATE,
Defendant.
____________________________________)
NOTICE JOINT PROPOSED ORDER
Attached hereto the parties Joint Proposed Order.
Dated: April 15, 2016
Respectfully submitted,
/s/ Michael Bekesha
Michael Bekesha
D.C. Bar No. 995749
JUDICIAL WATCH, INC.
425 Third Street S.W., Suite 800
Washington, 20024
(202) 646-5172
Counsel for Plaintiff Judicial Watch, Inc.
BENJAMIN MIZER
Principal Deputy Assistant Attorney General
MARCIA BERMAN
Assistant Director
/s/ Caroline Lewis Wolverton
CAROLINE LEWIS WOLVERTON (DC 496433)
Senior Trial Counsel
STEVEN MYERS (NY 4823043)
Trial Attorney
United States Department Justice
Civil Division, Federal Programs Branch Massachusetts Avenue, N.W.
Case 1:13-cv-01363-EGS Document Filed 04/15/16 Page
Washington, D.C. 20530
Tel.: (202) 514-0265
Fax: (202) 616-8470
Email: caroline.lewis-wolverton@usdoj.gov
Attorneys for Defendant
Case 1:13-cv-01363-EGS Document 65-1 Filed 04/15/16 Page
UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
____________________________________
JUDICIAL WATCH, INC.,
Plaintiff,
Civil Action No. 13-CV-1363 (EGS)
UNITED STATES DEPARTMENT
STATE,
Defendant.
____________________________________)
JOINT [PROPOSED] ORDER
This matter before the Court Plaintiff Judicial Watch Proposed Discovery Plan,
ECF No. 58-1.
The Court stated during the February 23, 2016 hearing that discovery
necessary for the Court determine, matter law, [whether] considering all the
circumstances this case, [the Department State State Department State has,
indeed, matter law, conducted adequate search ensure compliance with [Plaintiff
FOIA request[.] Transcript February 23, 2016 Motion Hearing Transcript 78.
view that statement, having considered Plaintiff proposed plan, State response, Plaintiff
reply, and the parties jointly proposed order, and recognizing that Defendant has not waived its
objection discovery, hereby ORDERED that:
The scope permissible discovery shall follows: the creation and operation clintonemail.com for State Department business, well the State Department approach
and practice for processing FOIA requests that potentially implicated former Secretary Clinton
and Ms. Abedin emails and State processing the FOIA request that the subject this
action. Plaintiff not entitled discovery matters unrelated whether State conducted
Case 1:13-cv-01363-EGS Document 65-1 Filed 04/15/16 Page
adequate search response Plaintiff FOIA request, including without limitation: the
substantive information sought Plaintiff its FOIA request this case, which involves the
employment status single employee; the storage, handling, transmission, protection
classified information, including cybersecurity issues; and any pending FBI law enforcement
investigations. the conclusion deposition State may elect good faith the record
have period three business days following the time that deposition transcript audiovisual
recording made available the parties within which review those portions the transcript audiovisual recording that may contain classified information, information specifically
exempted from disclosure statute, information about any pending FBI law enforcement
investigations, and, necessary, seek order precluding public release, quotation
paraphrase any inadvertently disclosed classified information, information specifically
exempted from disclosure statute, information about any pending FBI law enforcement
investigations. The decision elect the three-business-day period State sole discretion
and may not challenged.
Discovery shall conducted pursuant the Federal Rules Civil Procedure,
subject the scope and limitations herein.
Defendant shall serve its answers and any objections the four interrogatories set
forth Plaintiff proposed discovery plan, ECF No. 58-1 (Mar. 15, 2016), within days the
Court order.
Discovery shall completed within eight weeks the Court order. Plaintiff
reserves the right seek additional time necessary, and Defendant reserves the right object.
Plaintiff must seek the Court permission conduct discovery beyond the depositions identified
Case 1:13-cv-01363-EGS Document 65-1 Filed 04/15/16 Page paragraph its discovery plan and the interrogatories identified paragraph its
discovery plan, ECF No. 58-1, and Defendant reserves the right object.
Plaintiff removes Donald Reid from the list individuals identified
paragraph its discovery plan while reserving the right seek the Court permission take
his deposition later time, and State reserves the right object. ORDERED.
Dated ____________________
____________________________________
EMMET SULLIVAN
UNITED STATES DISTRICT JUDGE