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Judicial Watch • Pltf Status Rpt and Recommendation for Proceedings

Pltf Status Rpt and Recommendation for Proceedings

Pltf Status Rpt and Recommendation for Proceedings

Page 1: Pltf Status Rpt and Recommendation for Proceedings

Category:IRS Scandal

Number of Pages:3

Date Created:September 24, 2014

Date Uploaded to the Library:September 26, 2014

Tags:IRS Scandal, IRS

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Plaintiff, Civil Action No. 13-1559-EGS  
Plaintiff, Judicial Watch, Inc., counsel, and pursuant the Courts July 10, 2014 Minute Order, respectfully submits this Status Report the above-captioned matter.  Plaintiff also submits the Court its Recommendation for Further Proceedings individually the IRS does not joint Plaintiffs recommendation for limited discovery.    
The parties appeared before this Court for status conference July 10, 2014, after startling news reports indicated that large volume the records issue this FOIA litigation were missing due allegations multiple hard drive crashes.  Mot. For Status Conference,  (DKT No. 20).  During the July 10, 2014 status conference and subsequent Minute Orders dated July 10, 2014 and August 14, 2014, the Court ordered the IRS provide sworn declarations from agency officials describing, part, how the missing e-mails may retrieved from other sources, and what efforts, any, the IRS had undertaken obtain the missing e-mails from those sources.  The IRS provided two series inadequate declarations August 11, 2014 and August 22, 2014 that omitted material information about where and how the missing e-mails may retrieved.   
Consistent with the Courts instructions during the Status Conference held July 10, 2014, Plaintiff filed motion for limited discovery after September 10, 2014.  Judicial Watch filed the motion due serious questions posed the IRSs conflicting public reports about the missing e-mails and its failure disclose this Court material information about the IRSs system records and other sources for the missing e-mails. such, Judicial Watch respectfully proposes limited discovery obtain such highly relevant information for this case fairly adjudicated, and incorporates reference the facts and arguments set forth its motion for limited discovery fully asserted herein,, support its recommendation.  See generally Mot. for Limited Discovery (DKT No. 31).  Pursuant Defendants Notice September 10, 2014, limited discovery these issues would longer interfere with relevant investigation the Treasury Inspector General for Tax Administration.  IRS Notice (DKT No. 30). the IRS did not join Judicial Watchs recommendation for discovery, Judicial Watch has submitted its own report, consistent with the Courts July 10, 2014 Minute Order.  With respect the IRS request for thirteen-day extension respond Plaintiffs pending motion for limited discovery, Judicial Watch has advised agency counsel that seeks resolve this matter expeditiously possible.  However, will defer the Courts determination whether Defendant has shown good cause for the requested extension.   
Specific the IRS production records responsive Plaintiffs FOIA requests, the IRS has continued produce monthly productions, many which are heavily redacted.  Judicial Watch does not object the IRSs continued monthly rolling production and recommendation file status report January 15, 2015.  However, the IRS has still not provided estimated time frame for when will complete its document production and has continued produce records 
reverse chronological order, despite Judicial Watchs repeated request that future document productions are released chronological order.  The production reverse chronological order further delays the IRS disclosure the gaps for the missing records.  Judicial Watch respectfully requests that the Court order the IRS provide estimated time when will complete its production all non-exempt, responsive records and that all future productions documents are released chronological order, starting with the earliest records from January 2010.   
Judicial Watch, good faith effort narrow disputed issues this litigation, agreed with previous counsel for the IRS, Norah Bringer, narrow the scope Plaintiffs FOIA request referenced paragraph nine (9) Plaintiffs Complaint the actual number applications seeking 501(c)(4) status since January 2010.  Compl.,   Since the IRS was not required produce any records light the narrowed scope and since has provided the number such applications, Defendants satisfaction that FOIA request longer dispute.  Defendants production information requested the three other FOIA requests referenced Plaintiffs Complaint remain contested and under dispute this litigation.  Compl.,  10-12.  
 Dated:  September 24, 2014   Respectfully submitted, 
/S/ Ramona Cotca                   
Ramona Cotca, D.C. Bar No. 501159 
Judicial Watch, Inc. 
425 Third Street, SW, Suite 800 
Washington,  20024 
(202) 646-5172 
Attorneys for Plaintiff