Case 1:15-cv-00684-BAH Document 14 Filed 01/11/16 Page 1 of 3

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
JUDICIAL WATCH, INC.
Plaintiff,
v.

15-cv-684 (BAH)

U.S. DEPARTMENT OF STATE,
Defendant.
JOINT STATUS REPORT
Defendant the United States Department of State (“State”) and Plaintiff Judicial Watch,
Inc. (“Judicial Watch”) respectfully submit the following:
1. On June 26, 2015, the Court adopted State’s proposed production schedule, which
provided for rolling productions every sixty days beginning on August 31, 2015 and
concluding on January 29, 2016. State has made three productions in accordance
with that schedule.
2. State proposed that schedule before receiving three tranches of records from Huma
Abedin, see Mot. for a Stay Pending Resolution of Its Mot. for a Coordinating Judge
(ECF No. 9) at 1 (“Stay Mot.”); see also Reply to Pl.’s Opp’n. to Stay Mot. (ECF No.
12) at 3-4, totaling roughly twenty nine thousand pages (hereafter “recently received
documents”), all of which are potentially responsive to Plaintiff’s FOIA request, see
Compl. ¶ 5 (requesting “[a]ny and all emails of official State Department business
received or sent by former Deputy Chief of Staff Huma Abedin from January 1, 2009
through February 1, 2013 using a non-“state.gov” email address.”).

-1-

Case 1:15-cv-00684-BAH Document 14 Filed 01/11/16 Page 2 of 3

3. In its Stay Motion and its Reply to Plaintiff’s Opposition to that Motion, State
indicated its willingness to search the documents recently provided by Ms. Abedin.
4. The parties have agreed that State will produce to Judicial Watch responsive, nonexempt records from within the recently received documents, excluding news
clippings/briefings contained therein. To that end, the parties respectfully propose
that the current briefing schedule be suspended and that the Court adopt the following
schedule:
a. State will produce to Judicial Watch all responsive, non-exempt records from
within the recently received Abedin documents, excluding news
clippings/briefings, by April 30, 2017. State will provide rolling productions
every thirty days, beginning on March 1, 2016, reviewing a minimum of 400
pages per month.
b. The parties will provide joint status reports to the Court every ninety days,
beginning on May 30, 2016, updating the Court as to the status of productions.
c.

By May 15, 2017, the parties will provide the Court with a final status report
and, if necessary, a briefing schedule.

-2-

Case 1:15-cv-00684-BAH Document 14 Filed 01/11/16 Page 3 of 3

Date: January 11, 2016

Respectfully submitted,
BENJAMIN C. MIZER
Principal Deputy Assistant Attorney General
ELIZABETH J. SHAPIRO
Deputy Branch Director
/s/ Caroline Anderson
CAROLINE J. ANDERSON
(IL Bar No. 6308482)
United States Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Ave., N.W.
Washington, DC 20530
Tel: (202) 305-8645
Caroline.j.anderson@usdoj.gov
Counsel for Defendant
/s/ Michael Bekesha
Michael Bekesha
DC Bar No. 995749
JUDICIAL WATCH, INC.
425 Third Street, S.W., Suite 800
Washington, DC 20024
Counsel for Plaintiff

-3-

Sign up to vote on this title
UsefulNot useful