Case 1:10-cv-00751-RBW Document 10

Filed 03/11/11 Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA __________________________________________ VERN McKINLEY, ) ) Plaintiff, ) v. ) ) BOARD OF GOVERNORS OF THE ) FEDERAL RESERVE SYSTEM, ) ) Defendant. ) __________________________________________)

Case No: 10-00751 (RBW)

JOINT MOTION FOR EXTENSION OF TIME AND TO MODIFY BRIEFING SCHEDULE Plaintiff and Defendant, by and through undersigned counsel, move to modify the existing briefing schedule by extending the deadline for Defendant’s motion for summary judgment, currently set for March 21, 2011, by 49 days to May 9, 2011, and to adjust other deadlines in the schedule, and as grounds state: 1. This matter involves two FOIA requests directed to the Board of Governors of the

Federal Reserve System (the “Board”) as more fully described in the Complaint. (Compl. ¶ 5-6). Defendant answered the Complaint on July 1, 2010. 2. Defendant has released to Plaintiff what it contends to be all non-exempt

responsive documents to the FOIA requests at issue (totaling over 2,000 pages of documents) and, pursuant to the Court’s order dated December 3, 2010, Defendant has provided a draft Vaughn index to Plaintiff. Plaintiff has reviewed the draft Vaughn index, and pursuant to the referenced order, has identified for Defendant certain withholdings that Plaintiff does not intend to challenge. However, numerous withholdings based on several exemptions remain at issue in this action.

Case 1:10-cv-00751-RBW Document 10

Filed 03/11/11 Page 2 of 3

3.

Pursuant to the Court’s order of December 3, 2010, Defendant’s motion for

summary judgment is due March 21, 2011, and the remaining deadlines are as follows: Plaintiff’s opposition to motion for summary judgment and cross-motion for summary judgment Defendant’s reply in support of motion for summary judgment and opposition to Plaintiff’s cross-motion Plaintiff’s reply in support of Plaintiff’s cross-motion Status Conference April 18, 2011

May 23, 2011

June 20, 2011 September 20, 2011

4.

Due to the volume of documents at issue, as well as the number of exemptions

that remain to be briefed, Defendant requires additional time to prepare its summary judgment motion as well as the declarations that will be filed in support of that motion. 5. Accordingly, the parties have conferred and at this time propose the following

adjustments to the briefing schedule. Defendant’s motion for summary judgment Plaintiff’s opposition to motion for summary judgment and cross-motion for summary judgment Defendant’s reply in support of motion for summary judgment and opposition to Plaintiff’s cross-motion Plaintiff’s reply in support of Plaintiff’s cross-motion May 9, 2011 June 20, 2011

August 4, 2011

September 1, 2011

6.

These adjustments to the schedule will still result in briefing being completed

before the existing status conference scheduled for September 20, 2011. 7. A proposed order is attached.

Case 1:10-cv-00751-RBW Document 10

Filed 03/11/11 Page 3 of 3

Dated: March 11, 2011 /s/ MICHAEL BEKESHA D.C. Bar # 995749 JUDICIAL WATCH, INC. 425 Third Street, S.W., Suite 800 Washington, D.C. 20024 (202) 646-5172

Respectfully submitted, RONALD C. MACHEN JR., D.C. Bar #447889 United States Attorney for the District of Columbia RUDOLPH CONTRERAS, D.C. Bar #434122 Chief, Civil Division By: ________/s/____________________ JEREMY S. SIMON, D.C. BAR # 447956 Assistant United States Attorney Civil Division 555 4th Street, N.W. Washington, D.C. 20530 (202) 307-0406 Jeremy.Simon@usdoj.gov

Attorneys for Plaintiff

Attorneys for Defendant

Sign up to vote on this title
UsefulNot useful