Filed: Jan. 21, 2016
Latest Update: Jan. 21, 2016
Summary: STIPULATION CONCERNING BRIEFING SCHEDULE AND ORDER HAYWOOD S. GILLIAM, Jr. , District Judge . Pursuant to Local Rule 7-12, and this Court's January 20, 2016 order in the above-captioned case, Plaintiff Freedom of the Press Foundation ("FPF") and Defendant Department of Justice ("DOJ" or "Defendant") hereby stipulate and agree as follows: 1. On January 19, 2016, this Court held a Case Management Conference in this case. 2. After that Case Management Conference, this Court entered an order
Summary: STIPULATION CONCERNING BRIEFING SCHEDULE AND ORDER HAYWOOD S. GILLIAM, Jr. , District Judge . Pursuant to Local Rule 7-12, and this Court's January 20, 2016 order in the above-captioned case, Plaintiff Freedom of the Press Foundation ("FPF") and Defendant Department of Justice ("DOJ" or "Defendant") hereby stipulate and agree as follows: 1. On January 19, 2016, this Court held a Case Management Conference in this case. 2. After that Case Management Conference, this Court entered an order d..
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STIPULATION CONCERNING BRIEFING SCHEDULE AND ORDER
HAYWOOD S. GILLIAM, Jr., District Judge.
Pursuant to Local Rule 7-12, and this Court's January 20, 2016 order in the above-captioned case, Plaintiff Freedom of the Press Foundation ("FPF") and Defendant Department of Justice ("DOJ" or "Defendant") hereby stipulate and agree as follows:
1. On January 19, 2016, this Court held a Case Management Conference in this case.
2. After that Case Management Conference, this Court entered an order directing Defendant to prepare a draft Vaughn index explaining and justifying its withholding of records in response to FPF's Freedom of Information Act ("FOIA") request under applicable FOIA exemptions, and to exchange that index with FPF on or before March 21, 2016. See Doc. 24. This Court further directed the parties to meet and confer regarding a proposed briefing schedule in this case, and to submit a stipulation and proposed order. Id.
3. Accordingly, the parties have agreed to, and request that the Court approve, the below schedule in this case:
a. On or before March 30, 2016, FPF shall inform Defendant whether it believes motions practice will be necessary and, if so, the specific withholdings it intends to challenge.
b. On or before April 1, 2016, the parties shall file a Joint Case Management Statement informing the Court as to whether motions practice will be necessary.
c. If motions practice is deemed necessary by the parties, then the following briefing schedule will apply:
i. May 9, 2016 for Defendant's motion for summary judgment.
ii. June 10, 2016 for FPF's opposition to Defendant's motion, and any cross-motion for summary judgment by FPF.
iii. July 1, 2016 for Defendant's reply in support of Defendant's motion for summary judgment and opposition to FPF's cross-motion if a cross-motion is filed.
iv. July 25, 2016 for FPF's reply in support of FPF's cross-motion if a cross-motion is filed.
4. Accordingly, the parties respectfully request that the Court order the proposed schedule set forth above.
ORDER
Upon stipulation of the parties, the Court hereby orders the following schedule in this matter:
a. On or before March 30, 2016, FPF shall inform Defendant whether it believes motions practice will be necessary and, if so, the specific withholdings it intends to challenge.
b. On or before April 1, 2016, the parties shall file a Joint Case Management Statement informing the Court as to whether motions practice will be necessary.
c. If motions practice is deemed necessary by the parties, then the following briefing schedule will apply:
i. May 9, 2016 for Defendant's motion for summary judgment.
ii. June 10, 2016 for FPF's opposition to Defendant's motion, and any cross-motion for summary judgment by FPF.
iii. July 1, 2016 for Defendant's reply in support of Defendant's motion for summary judgment and opposition to FPF's cross-motion if a cross-motion is filed.
iv. July 25, 2016 for FPF's reply in support of FPF's cross-motion if a cross-motion is filed.
PURSUANT TO STIPULATION, IT IS SO ORDERED except that the hearing on the motion will be on August 11, 2016 at 2:00 p.m.
DECLARATION PURSUANT TO CIV. L.R. 5-1(i)(3)
I, Andrew M. Bernie, declare that I have obtained the concurrence in the filing of this Stipulation Concerning Briefing Schedule and [Proposed] Order from Marcia Hofman and Victoria Baranetsky, counsel for Plaintiff in this matter.
I declare under penalty of perjury that the foregoing is true and correct.
