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Case 1:19-cv-01260-RCL Document 9 Filed 06/18/19 Page 1 of 4

UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA
______________________________________
)
HAWAII FIREARMS COALITION, )
)
Plaintiff, )
)
v. ) Civil Action No. 19-1260 (RCL)
)
FEDERAL BUREAU OF INVESTIGATION, )
)
Defendant. )
______________________________________ )

JOINT MOTION TO VACATE BRIEFING SCHEDULE

Plaintiff Hawaii Firearms Coalition and Defendant the Federal Bureau of Investigation

(“FBI”), by and through their respective undersigned counsel, hereby jointly request that the

Court vacate the current deadline for Defendant’s dispositive motion in this Freedom of

Information Act (“FOIA”) case. In support of this motion, the Parties hereby state as follows:

1. Plaintiff has requested records from the FBI regarding Hawaii’s requirement that

firearms purchasers, registrants, and owners be included in the FBI’s Rap Back database. See

Complaint (ECF No. 1) at 6; Ex. A (ECF No. 1-1).

2. In a Minute Order dated June 7, 2019, the Court ordered the FBI to produce and

file a Vaughn index with a supporting dispositive motion within 30 days, pursuant to Local Rule

16.3(b)(10).

3. The FBI has not yet completed its response to Plaintiff’s FOIA request and is

currently conducting a search for all potentially responsive records to Plaintiff’s request.

4. In light of the FBI’s ongoing efforts to respond to Plaintiff’s FOIA request, the

Parties have conferred and believe that a briefing schedule in this case is premature.
Case 1:19-cv-01260-RCL Document 9 Filed 06/18/19 Page 2 of 4

Accordingly, the Parties respectfully request additional time for the FBI to complete its response

to Plaintiff’s request and also to permit the Parties to confer regarding any issues associated with

the FBI’s search or withholdings prior to the filing of any dispositive motion.

5. The FBI anticipates that it will complete its search for potentially responsive

records by June 28, 2019. After the FBI completes its search, the parties will confer regarding a

production schedule for the FBI’s release of any responsive non-exempt records to Plaintiff.

In light of the above, the Parties respectfully request that the Court vacate the current

deadline for the FBI to file a Vaughn index and dispositive motion. The Parties also request that

the Court permit the Parties to file a joint status report no later than July 31, 2019, further

updating the Court regarding the FBI’s progress in responding to Plaintiff’s FOIA request. The

Parties’ status report will include a proposed briefing schedule, if one is necessary.

A proposed order is attached.

Respectfully submitted,

/s/ Stephen D. Stamboulieh


Stephen D. Stamboulieh
Stamboulieh Law, PLLC
P.O. Box 4008
Madison, MS 39130
(601) 852-3440
stephen@sdslaw.us
DC District Court Bar# MS0009

Alan Alexander Beck


Law Office of Alan Beck
2692 Harcourt Drive
San Diego, CA 92123
(619) 905-9105
Hawaii Bar No. 9145
Alan.alexander.beck@gmail.com
DC District Court Bar# HI001

Counsel for Plaintiff

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Case 1:19-cv-01260-RCL Document 9 Filed 06/18/19 Page 3 of 4

JESSIE K. LIU, D.C. Bar. No. 472845


United States Attorney

DANIEL F. VAN HORN, D.C. Bar No. 924092


Chief, Civil Division

By: /s/ Christopher Hair


CHRISTOPHER HAIR, PA Bar No. 306656
Assistant United States Attorney
555 Fourth Street, N.W.
Washington, D.C. 20530
(202) 252-2541
christopher.hair@usdoj.gov

Counsel for Defendant

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Case 1:19-cv-01260-RCL Document 9 Filed 06/18/19 Page 4 of 4

UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA
______________________________________
)
HAWAII FIREARMS COALITION, )
)
Plaintiff, )
)
v. ) Civil Action No. 19-1260 (RCL)
)
FEDERAL BUREAU OF INVESTIGATION, )
)
Defendant. )
______________________________________ )

[PROPOSED] ORDER

In light of the Parties’ joint motion to vacate the briefing schedule, it is hereby

ORDERED that Defendant’s deadline to file a Vaughn index and supporting dispositive motion

is VACATED; and it is

ORDERED that the Parties shall file a joint status report on or before July 31, 2019,

further updating the Court regarding Defendant’s progress in responding to Plaintiff’s FOIA

request and proposing a schedule for further proceedings.

_________________________ ____________________________
Date Royce C. Lamberth
United States District Judge