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Judicial Watch • 14-1242 Opposition

14-1242 Opposition

14-1242 Opposition

Page 1: 14-1242 Opposition

Category:Legal Document

Number of Pages:12

Date Created:September 21, 2015

Date Uploaded to the Library:October 02, 2015


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Case 1:14-cv 1242 RCL Document Filed 09/21/15 Page THE UNITED STAT TRICT COURT DISTRICT COLUMBIA
Civil Action No, 14-1242 (RCL)
Plaintiffjudieial Watch, Inc.. and through counsel, respectfully submits this
opposition Defendanfs Motion Stay Pending Resulution oflts Motion for Designation
Coordinating Judge. grounds tlterefm Plaintitt ales tbllm
There nothing gained Defendant request for stay ufthe proceedings
there action left uit the cemdinatingjutlg:. Defendant seeks
its pending eoerdinutiun motion. Defentkmt conducted the searches alleges was ohligated complete under the Freedom otlI1forma1im1 Act FOIA and moved forjudgmenl
matter oflaw Plaintiffc -moved for discovery under Rule 56(d) and now Defendant seeks inde nite ofthe cdings pending its request for coortlinatingjudge wersee
searclt ofrecords Defendant claims under obligation take this ction. Either the
motion stay tiivolous Defendant claims already completed the search hligated undertake under FOIA Detendant motion for summary judgment tiivolous ifit now
claims that gated under FOIA the ords returned Cheryl Mills. Huma
Case 1:14 O1242~RCL Document Filed 09/21/15 Page
Abedin and Jacob Sullivan. the latter scenario, the appropriate action for Defendant would withdraw its motion for S1ll llI1 judgment not seek further delay its obligations under
II. Factual background and procedural history.
Subject FOIA. Plaintiff submitted request for all res. from the Office ofthe
Secretary that relate copie updates and/01 ununications about the talking points provided Ambz dor Rice the White House any federal agency concerning the September
2012 attack the US. consulate Benghazi, Libya. Compl. The parties agree that
records frmn Secret Clinton and three her senior aide Mills, Huma Abedin and
Jacob Sullivan, are relevant Plaintift FOIA request.
uly 2015, Defendant moved for summa judgment the grounds that did what was obligated under FOIA. Sec Def. Motion for Summary Judgment Def SJM (EC
No. 19). response, Plaintiffmoved for discovery pursuant Rule 56(d_). SUB Pltf. Mot.
Allow Time for Limited Discove Pursuant Rule 56(d) Pltf. Rule (d) Mot. ECF No.
22). Defendant led its opposition Plaintifts Rule 56(d) motion Frida eptemher 18,
where alleg nee more that under obli search the records received
from Ms. Mills, Mr. Sulli ill and Ms, Ahedin subsequent the tiling its motion for summary
lgmen icy Def. Opposition Pltf. Rule 564d) Mot. No. 27).
After moved for sunn dgmei Defendant now seeks stay proceedings this well other FOIA lawsuits (not the represented Defendant )rdinution pending its motion for eoordinatingjudge oversee the Search and odueiion
trecnrds from Phillipe Reines are all relevant the FOIA request light
Defendant failure records manage emails the
Case 1:14-cv-01242-RCL Document Filed 09/21/15 Page
records returned Defendant front Secretary Clinton, Ms. Mills. Ms. Abedin, Mr. Sullivan and
Mr. Reines. See Def. Mot for Stay Pending Resolution its Motion for Designation
inating Judge (De Mot. for St- (ECF No. 25); Def. Mot. for Designation
Cool inating Judge, De]: 1;] State FOIA Liligulirm