1
THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
 __________________________________________ ) JASON LEOPOLD, ) ) Plaintiff, ) ) v. ) ) Case No. 15-cv-02117 RDM U.S. DEPARTMENT OF JUSTICE ) ) Defendant. )  __________________________________________)
MOTION FOR SUMMARY JUDGMENT
Pursuant to 5 U.S.C. § 552(b)(7)(A), Federal Rule of Civil Procedure 56, Local Rule 7, and this Court’s Minute Order of February 9, 2016, Defendant, the United States Department of Justice (“DOJ” or “Defendant”) respectfully moves for summary  judgment. The reasons for this Motion are set forth in the Memorandum of Points and Authorities in Support of Defendant’s Motion for Summary Judgment, the Statement of Material Facts as to Which There Is No Genuine Issue, the Declaration of David M. Hardy (as well as the exhibits thereto), and a classified declaration, which has been submitted for the Court’s
in camera
,
ex parte
 review. A proposed order is filed concurrently herewith. Dated: March 25, 2016 Respectfully submitted, BENJAMIN C. MIZER Principal Deputy Assistant Attorney General MARCIA BERMAN Assistant Branch Director
 /s/ Jennie L. Kneedler
Case 1:15-cv-02117-RDM Document 7 Filed 03/25/16 Page 1 of 29
 
2 JENNIE L. KNEEDLER Trial Attorney United States Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Ave., N.W. Washington, D.C. 20001 Tel. (202) 305-8662 Fax (202) 616-8470 Email: Jennie.L.Kneedler@usdoj.gov D.C. Bar # 500261
Case 1:15-cv-02117-RDM Document 7 Filed 03/25/16 Page 2 of 29
 
1
THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
 __________________________________________ ) JASON LEOPOLD, ) ) Plaintiff, ) ) v. ) ) Case No. 15-cv-02117 RDM U.S. DEPARTMENT OF JUSTICE ) ) Defendant. )  __________________________________________)
DEFENDANT’S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE
 Pursuant to Local Rule 7(h)(1), Defendant respectfully submits the following statement of material facts as to which there is no genuine issue: 1. On November 3, 2015, plaintiff submitted a Freedom of Information Act (“FOIA”) request to the Federal Bureau of Investigation (“FBI”) via electronic mail. The request sought the following categories of records from December 1, 2014 through the date of the search: a. Any and all emails and other records retrieved from the server, thumb drive, and any other electronic equipment obtained either directly or indirectly from Hillary Clinton (collectively and individually the “Clinton Server”) which has not already been made public; and  b. Any and all correspondence and other records regarding, relating to, or referencing authorization for anyone within the FBI to disclose to the media or any other person or entity outside the FBI the seizure, confiscation, or taking  possession of the Clinton Server; and c. Any and all correspondence and other records regarding, relating to, or referencing authorization for anyone within the FBI to disclose to the media or any other person or entity outside the FBI whether and what information has  been obtained from the Clinton Server; and
Case 1:15-cv-02117-RDM Document 7 Filed 03/25/16 Page 3 of 29
View on Scribd
Back to document