STIPULATED REQUEST FOR CONTINUANCE OF SUMMARY JUDGMENT BRIEFING TO PERMIT REPROCESSING OF DOCUMENT AND [PROPOSED] ORDER

RICHARD SEEBORG, District Judge.

Pursuant to Civil L.R. 6-2, Defendants hereby request a continuance of the upcoming summary judgment briefing for Defendants to complete reprocessing of the single document responsive to Plaintiff's May 6, 2014 Freedom of Information Act ("FOIA") requests that remains in contention in this matter. In support of this motion, the Government states as follows:

1. Throughout this litigation, the parties have worked to narrow the scope of the issues in this action. After the parties agreed to a narrowing of Plaintiff's FOIA requests, Defendants produced 16 responsive documents, all of which contained redactions pursuant to claimed FOIA exemptions. Defendants also withheld in full 107 documents responsive to Plaintiff's requests.

2. The parties conferred after the completion of the Defendants' production, and agreed that the only issue remaining in contention in this matter is one record withheld in full pursuant to FOIA exemptions (b)(1), (b)(3), and (b)(5). See Joint Case Management Statement, ECF No. 24, at 5. The parties then submitted a proposed schedule for summary judgment briefing regarding that issue. See id.

3. The Court adopted the parties' proposed summary judgment briefing schedule in an Order dated May 19, 2015. See Order Adopting Proposed Briefing Schedule and Vacating Case Management Conference, ECF No. 25.

4. Under the current schedule:

Id. at 1.

5. Defendants have now determined that the single document that remains in contention in this case may be reprocessed and released in part. Defendants have begun that process and anticipate that they will be able to produce a redacted version of the document to Plaintiff by September 3.

6. Plaintiff has agreed to review the reprocessed document, in conjunction with a Vaughn index for that document, to determine whether it is satisfied with the disclosure or whether it will challenge the redactions taken in the document. Plaintiff has agreed to inform the Defendants of how it wishes to proceed by September 17, 2015.

7. At that time, the parties propose to file an update with the Court, informing the Court of whether any substantive matters remain in contention, and, if so, proposing a new schedule for summary judgment briefing that would begin in October 2015.

8. The requested continuance would suspend the deadlines currently on the calendar in this matter. The parties respectfully request this relief to enable them to confer regarding the reprocessed document, and to avoid potentially unnecessary briefing regarding the merits of this matter.

9. There have been no prior extensions or continuances as to the summary judgement briefing schedule described in paragraph 4.

For all of these reasons, the parties respectfully request that the Court continue the current summary judgment briefing schedule and order that the parties submit a status report, including, if any substantive matters remain in contention, a new proposed summary judgment briefing schedule by September 25, 2015.

PURSUANT TO STIPULATION, it is hereby ORDERED that the current summary judgment briefing schedule is continued, and it is further ORDERED that the parties shall submit a status report, including, if any substantive matters remain in contention, a new proposed summary judgment briefing schedule by September 25, 2015.

IT IS SO ORDERED.