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Page 1 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
DEMOCRATIC NATIONAL
COMMITTEE
Plaintiff,
v.
UNITED STATES DEPARTMENT
OF JUSTICE
Civil Action No. 07-712 (ESH)
Defendant.
JOINT BRIEFING SCHEDULE STATEMENT
Pursuant to the parties’ Joint Meet and Confer Statement and the Court’s minute order
entered on June 27, 2007, the parties have conferred and hereby submit this joint report.
1.
This action arises under the Freedom of Information Act (“FOIA”), 5 U.S.C. §
552, as amended, as well as agency FOIA regulations. Plaintiff the Democratic National
Committee alleges that the Defendant United States Department of Justice has violated FOIA in
connection with Plaintiff’s March 19, 2007 FOIA request to the Defendant. Defendant denies
that it has violated FOIA.
2.
The parties filed a Joint Meet and Confer Statement on June 27, 2007 (dkt. no. 4),
notifying the Court that Defendant had made substantial progress in identifying documents
potentially responsive to Plaintiff’s FOIA request, but its search was not yet completed.
Accordingly, among other things, the parties agreed to defer the time for submitting any
proposed schedule for the briefing of dispositive motions until August 31, 2007, at which time
Defendant would be in a position to estimate what additional time was required for completing
1Page 2 its substantive review of the responsive documents. The Court entered the parties’ proposed
schedule by minute order dated June 27, 2007.
3.
On August 31, 2007, Defendant notified the Court that it had completed its search
for documents potentially responsive to Plaintiff’s FOIA request, but it had not yet completed its
processing of those documents. Accordingly, the parties agreed that Defendant would produce
documents that are not withheld under FOIA as they become available on a rolling basis, and
that, based on Defendant’s then current estimate as to its ability to resolve Plaintiff’s FOIA
request, Defendant would complete its processing of Plaintiff’s FOIA request and provide
Plaintiff with a draft Vaughn index by October 31, 2007.
4.
Defendant has not yet completed the processing of those documents potentially
responsive to Plaintiff’s FOIA request. Defendant has, however, continued to produce additional
documents, not withheld under FOIA, to Plaintiff on October 23, 2007, and on October 31, 2007.
The parties have agreed Defendant will complete its processing of Plaintiff’s FOIA request and
provide Plaintiff with a draft Vaughn index by November 16, 2007.
5.
In light of the agreed-upon processing schedule, the parties will maintain the
current dispositive briefing schedule:
December 7, 2007
Defendant’s Dispositive Motion
December 21, 2007
Plaintiff’s Opposition to Defendant’s Dispositive Motion
January 11, 2008
Defendant’s Reply to Plaintiff’s Opposition
2Page 3 Respectfully submitted,
/s/ Joseph E. Sandler
Joseph E. Sandler
D.C. Bar # 255919
Sandler Reiff & Young, P.C.
50 E Street, S.E. #300
Washington, D.C. 20003
Tel: (202) 479-1111
Fax: (202) 479-1115
PETER D. KEISLER
Assistant Attorney General
JEFFREY A. TAYLOR
United States Attorney
JOHN TYLER (D.C. Bar No.
297713)
Senior Trial Counsel
Federal Programs Branch
Attorneys for Plaintiff
/s/ Nicholas A. Oldham
Nicholas A. Oldham (D.C. Bar No. 484113)
Trial Attorney
U.S. Department of Justice
Civil Division, Federal Programs
Branch
Mailing Address
P.O. Box 883
Washington, D.C. 20044
Delivery Address
20 Massachusetts Ave., N.W., Rm.
6134
Washington, D.C. 20001
Tel: (202) 514-3367
Fax: (202) 616-8470
nicholas.oldham@usdoj.gov
Attorneys for Defendant
Date: October 31, 2007
3Page 4 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
DEMOCRATIC NATIONAL
COMMITTEE
Plaintiff,
v.
UNITED STATES DEPARTMENT
OF JUSTICE
Civil Action No. 07-712 (ESH)
Defendant.
[PROPOSED] ORDER
HAVING CONSIDERED the Parties’ Joint Briefing Schedule Statement, it is hereby this
____ day of October 2007, ORDERED that:
1.
The Defendant shall complete its processing of Plaintiff’s Freedom of
Information Act request on or before November 16, 2007.
2.
The Defendant shall provide Plaintiff with a draft Vaughn index on or before
November 16, 2007.
3.
The dispositive briefing schedule shall remain unchanged.
4.
The Defendant shall file its dispositive motion on or before December 7, 2007.
5.
The Plaintiff shall file its opposition to Defendant’s dispositive motion on or
before December 21, 2007.
6.
The Defendant shall file its reply to Plaintiff’s opposition on or before January
11, 2008.
__________________________________
ELLEN SEGAL HUVELLE
UNITED STATES DISTRICT JUDGE
1
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:07-cv-00712-ESH
Document 6
Filed 10/31/2007
Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
DEMOCRATIC NATIONAL
COMMITTEE
Plaintiff,
v.
UNITED STATES DEPARTMENT
OF JUSTICE
Civil Action No. 07-712 (ESH)
Defendant.
JOINT BRIEFING SCHEDULE STATEMENT
Pursuant to the parties’ Joint Meet and Confer Statement and the Court’s minute order
entered on June 27, 2007, the parties have conferred and hereby submit this joint report.
1.
This action arises under the Freedom of Information Act (“FOIA”), 5 U.S.C. §
552, as amended, as well as agency FOIA regulations. Plaintiff the Democratic National
Committee alleges that the Defendant United States Department of Justice has violated FOIA in
connection with Plaintiff’s March 19, 2007 FOIA request to the Defendant. Defendant denies
that it has violated FOIA.
2.
The parties filed a Joint Meet and Confer Statement on June 27, 2007 (dkt. no. 4),
notifying the Court that Defendant had made substantial progress in identifying documents
potentially responsive to Plaintiff’s FOIA request, but its search was not yet completed.
Accordingly, among other things, the parties agreed to defer the time for submitting any
proposed schedule for the briefing of dispositive motions until August 31, 2007, at which time
Defendant would be in a position to estimate what additional time was required for completing
1
PDF Page 3
Case 1:07-cv-00712-ESH
Document 6
Filed 10/31/2007
Page 2 of 3
its substantive review of the responsive documents. The Court entered the parties’ proposed
schedule by minute order dated June 27, 2007.
3.
On August 31, 2007, Defendant notified the Court that it had completed its search
for documents potentially responsive to Plaintiff’s FOIA request, but it had not yet completed its
processing of those documents. Accordingly, the parties agreed that Defendant would produce
documents that are not withheld under FOIA as they become available on a rolling basis, and
that, based on Defendant’s then current estimate as to its ability to resolve Plaintiff’s FOIA
request, Defendant would complete its processing of Plaintiff’s FOIA request and provide
Plaintiff with a draft Vaughn index by October 31, 2007.
4.
Defendant has not yet completed the processing of those documents potentially
responsive to Plaintiff’s FOIA request. Defendant has, however, continued to produce additional
documents, not withheld under FOIA, to Plaintiff on October 23, 2007, and on October 31, 2007.
The parties have agreed Defendant will complete its processing of Plaintiff’s FOIA request and
provide Plaintiff with a draft Vaughn index by November 16, 2007.
5.
In light of the agreed-upon processing schedule, the parties will maintain the
current dispositive briefing schedule:
December 7, 2007
Defendant’s Dispositive Motion
December 21, 2007
Plaintiff’s Opposition to Defendant’s Dispositive Motion
January 11, 2008
Defendant’s Reply to Plaintiff’s Opposition
2
PDF Page 4
Case 1:07-cv-00712-ESH
Document 6
Filed 10/31/2007
Page 3 of 3
Respectfully submitted,
/s/ Joseph E. Sandler
Joseph E. Sandler
D.C. Bar # 255919
Sandler Reiff & Young, P.C.
50 E Street, S.E. #300
Washington, D.C. 20003
Tel: (202) 479-1111
Fax: (202) 479-1115
PETER D. KEISLER
Assistant Attorney General
JEFFREY A. TAYLOR
United States Attorney
JOHN TYLER (D.C. Bar No.
297713)
Senior Trial Counsel
Federal Programs Branch
Attorneys for Plaintiff
/s/ Nicholas A. Oldham
Nicholas A. Oldham (D.C. Bar No. 484113)
Trial Attorney
U.S. Department of Justice
Civil Division, Federal Programs
Branch
Mailing Address
P.O. Box 883
Washington, D.C. 20044
Delivery Address
20 Massachusetts Ave., N.W., Rm.
6134
Washington, D.C. 20001
Tel: (202) 514-3367
Fax: (202) 616-8470
nicholas.oldham@usdoj.gov
Attorneys for Defendant
Date: October 31, 2007
3
PDF Page 5
Case 1:07-cv-00712-ESH
Document 6-2
Filed 10/31/2007
Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
DEMOCRATIC NATIONAL
COMMITTEE
Plaintiff,
v.
UNITED STATES DEPARTMENT
OF JUSTICE
Civil Action No. 07-712 (ESH)
Defendant.
[PROPOSED] ORDER
HAVING CONSIDERED the Parties’ Joint Briefing Schedule Statement, it is hereby this
____ day of October 2007, ORDERED that:
1.
The Defendant shall complete its processing of Plaintiff’s Freedom of
Information Act request on or before November 16, 2007.
2.
The Defendant shall provide Plaintiff with a draft Vaughn index on or before
November 16, 2007.
3.
The dispositive briefing schedule shall remain unchanged.
4.
The Defendant shall file its dispositive motion on or before December 7, 2007.
5.
The Plaintiff shall file its opposition to Defendant’s dispositive motion on or
before December 21, 2007.
6.
The Defendant shall file its reply to Plaintiff’s opposition on or before January
11, 2008.
__________________________________
ELLEN SEGAL HUVELLE
UNITED STATES DISTRICT JUDGE
1
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