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Judicial Watch • Proposed Scheduling Order

Proposed Scheduling Order

Proposed Scheduling Order

Page 1: Proposed Scheduling Order

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Number of Pages:3

Date Created:September 30, 2013

Date Uploaded to the Library:May 06, 2014

Tags:SCHEDULE, parties, responsive, documents, Benghazi, request, White House, DOJ, department, united, EPA, ICE, CIA


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Case 1:13-cv-00951-EGS Document Filed 09/30/13 Page 
UNITED STATES DISTRICT COURT
 FOR THE DISTRICT COLUMBIA 

JUDICIAL WATCH, INC. 
Plaintiff, 
Civil Action No. 13-cv-00951 (EGS) 
U.S. DEPARTMENT STATE, Defendant. 

JOINT STATUS REPORT AND 
PROPOSED SCHEDULE FOR FURTHER PROCEEDINGS 

The parties, counsel, respectfully submit this Joint Status Report and Proposed Schedule for Further Proceedings response the Courts September 2013 Minute Order. BACKGROUND Judicial Watch, Inc., mailed Freedom Information Act (FOIA) request the U.S. Department State (Department) October 18, 2012, requesting Copies any updates and/or talking points given Ambassador Rice the White House any federal agency concerning, regarding, related the September 2012 attack the U.S. consulate Benghazi, Libya. Any and all records communications concerning, regarding, relating talking points updates the Benghazi attack given Ambassador Rice the White House any federal 
agency. See Compl.  June 21, 2013, ECF No. The Department acknowledged receipt the request October 26, 2012, assigning Case Control Number F-2012-38774. The Department was processing the request when Judicial Watch filed suit June 21, 2013, although had not produced any documents provided response other than its acknowledgment letter October 
Case 1:13-cv-00951-EGS Document Filed 09/30/13 Page 
26, 2012. The Department answered the complaint August 16, 2013. See Answer, Aug. 16, 2013, ECF No. 
STATUS THE REQUEST 
The Department has conducted searches for potentially responsive records and located upwards one thousand pages documents that will need reviewed the FOIA office order determine which documents, any, are responsive Judicial Watchs request. Due the large volume materials reviewed and the likely need for coordination with other United States government agencies, significant amount time will required process the records and determine which documents are responsive and which documents portions documents are subject release under the FOIA. 
The parties have agreed that the Department will make rolling productions material that determines both responsive Judicial Watchs FOIA request and subject release under the FOIA, with initial production date October 31, 2013, further production dates December 19, 2013 and February 20, 2014, and final production date April 17, 2014. order facilitate discussions attempt resolve this litigation without further adjudication, the Department will provide Judicial Watch May 2014 draft Vaughn index identifying the nature any information responsive records that the Department has withheld, any, and the reason for any such withholding (including relevant FOIA exemptions).1 Should this case proceed dispositive motions, this draft would without prejudice to, and would not limit waive, any justification argument the Department may raise defense any withholding that subject dispute, regardless whether such arguments justifications were included the draft. 
Case 1:13-cv-00951-EGS Document Filed 09/30/13 Page 
SCHEDULE 

There may may not need for summary judgment briefing this case. The parties 
therefore respectfully propose that, later than June 2014, the parties shall file second 
joint status report setting forth proposed schedule for subsequent proceedings, including 
proposed briefing schedule should the parties unable resolve this litigation without further 
adjudication. 
Date: Sep. 30, 2013 	Respectfully submitted, 
JUDICIAL WATCH, INC.  	STUART DELERY Assistant Attorney General 
/s/ Ramona Cotca 
RAMONA COTCA 	RONALD MACHEN 
(D.C. Bar No. 501159) 	United States Attorney 
425 Third Street, SW, Suite 800  Washington, 20024 ELIZABETH SHAPIRO 
(202) 646-5172, ext. 328 	Deputy Branch Director 
Counsel for Plaintiff 	/s/ Robert Prince 
ROBERT PRINCE (D.C. Bar No. 975545) United States Department Justice Civil Division, Federal Programs Branch Massachusetts Ave., N.W. Washington, 20530 Tel: (202) 305 3654 robert.prince@usdoj.gov 
Counsel for Defendant