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Judicial Watch • Joint Status Report JW v State 0690

Joint Status Report JW v State 0690

Joint Status Report JW v State 0690

Page 1: Joint Status Report JW v State 0690

Category:Legal Document

Number of Pages:3

Date Created:June 29, 2015

Date Uploaded to the Library:June 30, 2015

Tags:0690, dispositive, burke, caroline, Briefing, Lauren, SCHEDULE, Joint, parties, deputy, Civil, motion, Counsel, defendant, filed, plaintiff, document, department, FOIA, Washington, district, report


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Case 1:15-cv-00690-RMC Document Filed 06/29/15 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
Plaintiff,
U.S. DEPARTMENT STATE,
Defendant.
Civil Action No. 15-cv-690 (RMC)
JOINT STATUS REPORT
Pursuant the Court June 15, 2015 Order requiring the submission joint
dispositive motion briefing schedule, Plaintiff Judicial Watch, Inc. and Defendant U.S.
Department State, and through counsel, respectfully submit this Joint Report: March 2015, Plaintiff submitted two FOIA requests Defendant
seeking access records. Plaintiff initiated the above-captioned lawsuit May 2015. Defendant filed its Answer June 11, 2015. The parties have met and conferred, and submit their joint proposed briefing
schedule below: Defendant will complete all searches and produce Plaintiff all
responsive, non-privileged, and non-exempt records within its possession,
custody, control later than August 14, 2015. The Parties will meet and confer and file status report August 28,
2015 indicating whether additional briefing necessary. additional
Case 1:15-cv-00690-RMC Document Filed 06/29/15 Page
briefing necessary, the Parties will propose briefing schedule, which
may based upon the following schedule: Defendant will file its dispositive motion later September 28,
2015.
ii. Plaintiff will file its dispositive motion and opposition
Defendant dispositive motion October 28, 2015.
iii. Defendant will file its reply support its dispositive motion
and its opposition Plaintiff dispositive motion November
30, 2015.
iv. Plaintiff will file its reply support its dispositive motion December 14, 2015.
Dated: June 29, 2015
Respectfully submitted,
/s/
Lauren Burke
Lauren Burke
JUDICIAL WATCH, INC.
425 Third Street, S.W., Suite 800
Washington, 20024
Counsel for Plaintiff
BENJAMIN MIZER
Principal Deputy Assistant Attorney
General
ELIZABETH SHAPIRO
Deputy Director
/s/ Caroline Anderson
CAROLINE ANDERSON
Trial Attorney
U.S. Department Justice
Case 1:15-cv-00690-RMC Document Filed 06/29/15 Page
Civil Division
Federal Programs Branch Massachusetts, Avenue, N.W.
Washington, 20530
Tel: (202) 305-8645
Fax: (202) 616-8470
Caroline.J.Anderson@usdoj.gov
Counsel for the Defendant