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Case TitleGLOBAL HEALTH PROMISE v. FEDERAL BUREAU OF INVESTIGATION
DistrictDistrict of Columbia
CityWashington, DC
Case Number1:2020cv03564
Date Filed2020-12-08
Date ClosedOpen
JudgeJudge Carl J. Nichols
PlaintiffGLOBAL HEALTH PROMISE
Case DescriptionGlobal Health Promise submitted a FOIA request to the FBI for records concerning communications pertaining to the Highway Serial Killings Initiative and Operation Cross Country. The agency acknowledged receipt of the request. The agency divided the request in two separate requests. The agency disclosed records on Operation Cross Country although Global Health Promise alleged they were not responsive to the request. Global Health Promise filed an administrative appeal but after hearing nothing further from the agency, Global Health Promise filed suit.
Complaint issues: Failure to respond within statutory time limit, Adequacy - Search, Litigation - Attorney's fees

DefendantFEDERAL BUREAU OF INVESTIGATION
Documents
Docket
Complaint
Complaint attachment 1
Complaint attachment 2
Complaint attachment 3
Complaint attachment 4
Complaint attachment 5
Complaint attachment 6
Complaint attachment 7
Complaint attachment 8
Complaint attachment 9
Complaint attachment 10
Complaint attachment 11
Complaint attachment 12
User-contributed Documents
 
Docket Events (Hide)
Date FiledDoc #Docket Text

2020-12-081COMPLAINT against FEDERAL BUREAU OF INVESTIGATION ( Filing fee $ 402 receipt number ADCDC-7929263) filed by GLOBAL HEALTH PROMISE. (Attachments: # 1 Civil Cover Sheet, # 2 Summons FBI, # 3 Summons USAG, # 4 Summons USAO, # 5 Exhibit A, # 6 Exhibit B, # 7 Exhibit C, # 8 Exhibit D, # 9 Exhibit E, # 10 Exhibit F, # 11 Exhibit G, # 12 Exhibit H)(Sorenson, C.) (Entered: 12/08/2020)
2020-12-08Case Assigned to Judge Carl J. Nichols. (adh, ) (Entered: 12/08/2020)
2020-12-082SUMMONS (3) Issued Electronically as to FEDERAL BUREAU OF INVESTIGATION, U.S. Attorney and U.S. Attorney General (Attachment: # 1 Notice and Consent)(adh, ) (Entered: 12/08/2020)
2020-12-083STANDING ORDER. Signed by Judge Carl J. Nichols on December 8, 2020. (lccjn2) (Entered: 12/08/2020)
2021-02-034CERTIFICATE OF SERVICE by GLOBAL HEALTH PROMISE . (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Sorenson, C.) (Entered: 02/03/2021)
2021-02-04NOTICE OF ERROR re 4 Certificate of Service; emailed to petesorenson@gmail.com, cc'd 2 associated attorneys -- The PDF file you docketed contained errors: 1. Incorrect event used, 2. FYI: Please refile using correct Return of Service Executed event. (zeg, ) (Entered: 02/04/2021)
2021-02-255NOTICE of Appearance by Christopher Charles Hair on behalf of FEDERAL BUREAU OF INVESTIGATION (Hair, Christopher) (Entered: 02/25/2021)
2021-02-256ANSWER to Complaint by FEDERAL BUREAU OF INVESTIGATION.(Hair, Christopher) (Entered: 02/25/2021)
2021-03-03MINUTE ORDER. Before the Court in this Freedom of Information Act case are a Complaint and an Answer. According to Local Civil Rule 16.3, the requirements of Federal Rule of Civil Procedure 26(f) are inapplicable. It is hereby ORDERED that the Parties shall confer and file a Joint Status Report on or before March 17, 2021. The Joint Status Report shall address: (1) the status of Plaintiff's FOIA request; (2) the anticipated number of documents responsive to Plaintiff's FOIA request; (3) the anticipated date(s) for release of the documents requested by Plaintiff; (4) whether a motion for stay is likely under Open America v. Watergate Special Prosecution Force , 547 F.2d 605 (D.C. Cir. 1976); (5) the possibility of prioritizing documents responsive to Plaintiff's request[s] and any discussions regarding whether Plaintiff's request[s] can be narrowed; and (6) whether the Parties anticipate summary judgment briefing and, if so, a proposed briefing schedule. Signed by Judge Carl J. Nichols on March 3, 2021. (lccjn2) (Entered: 03/03/2021)
2021-03-177Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Hair, Christopher) (Entered: 03/17/2021)
2021-03-24MINUTE ORDER. Upon review of the Parties' 7 Joint Status Report, it is hereby ORDERED that the Parties shall file a Joint Status Report by May 17, 2021. Signed by Judge Carl J. Nichols on March 24, 2021. (lccjn2) (Entered: 03/24/2021)
2021-03-24Set/Reset Deadlines: Joint Status Report due by 5/17/2021. (zcal) (Entered: 03/24/2021)
2021-05-128Unopposed MOTION for Leave to File Amended Complaint by GLOBAL HEALTH PROMISE. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Sorenson, C.) (Entered: 05/12/2021)
2021-05-179Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Hair, Christopher) (Entered: 05/17/2021)
2021-05-18MINUTE ORDER. Upon review of Plaintiff's 8 Motion for Leave to File an Amended Complaint, it is hereby ORDERED that the Motion is GRANTED. Plaintiff shall file its Amended Complaint by May 24, 2021. It is further ORDERED that the Parties shall file a Joint Status Report by July 16, 2021. Signed by Judge Carl J. Nichols on May 18, 2021. (lccjn2) (Entered: 05/18/2021)
2021-05-18Set/Reset Deadlines: Amended Complaint due by 5/24/2021. Joint Status Report due by 7/16/2021. (zcal) (Entered: 05/18/2021)
2021-05-1810AMENDED COMPLAINT against FEDERAL BUREAU OF INVESTIGATION filed by GLOBAL HEALTH PROMISE. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F)(Sorenson, C.) (Entered: 05/18/2021)
2021-06-0111ANSWER to 10 Amended Complaint by FEDERAL BUREAU OF INVESTIGATION.(Hair, Christopher) (Entered: 06/01/2021)
2021-07-1412Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Hair, Christopher) (Entered: 07/14/2021)
2021-07-19MINUTE ORDER. Upon review of the Parties' 12 Joint Status Report, it is hereby ORDERED that the Parties shall file a Joint Status Report by November 17, 2021. Signed by Judge Carl J. Nichols on July 19, 2021. (lccjn2) (Entered: 07/19/2021)
2021-07-19Set/Reset Deadlines: Joint Status Report due by 11/17/2021. (zcal) (Entered: 07/21/2021)
2021-11-1713Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Hair, Christopher) (Entered: 11/17/2021)
2021-11-18MINUTE ORDER. Upon review of the 13 Joint Status Report, it is ORDERED that the Parties shall file an updated Joint Status Report on or before March 17, 2022. Signed by Judge Carl J. Nichols on November 18, 2021. (lccjn2) (Entered: 11/18/2021)
2021-11-18Set/Reset Deadlines: Joint Status Report due by 3/17/2021. (zcal) (Entered: 11/19/2021)
2022-03-1714Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Hair, Christopher) (Entered: 03/17/2022)
2022-03-28MINUTE ORDER. Upon review of the 14 Joint Status Report, it is ORDERED that the Parties shall file an updated Joint Status Report on or before May 16, 2022. Signed by Judge Carl J. Nichols on March 28, 2022. (lccjn2) (Entered: 03/28/2022)
2022-03-28Set/Reset Deadlines: Joint Status Report due by 5/16/2022. (zcal) (Entered: 03/28/2022)
2022-05-1615NOTICE OF SUBSTITUTION OF COUNSEL by Darrell C. Valdez on behalf of FEDERAL BUREAU OF INVESTIGATION Substituting for attorney Christopher Hair (Valdez, Darrell) (Entered: 05/16/2022)
2022-05-1616Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Valdez, Darrell) (Entered: 05/16/2022)
2022-05-23MINUTE ORDER. Upon review of the 16 Joint Status Report, it is ORDERED that the Parties shall file an updated Joint Status Report on or before July 15, 2022. Signed by Judge Carl J. Nichols on May 23, 2022. (lccjn2) (Entered: 05/23/2022)
2022-05-23Set/Reset Deadlines: Joint Status Report due by 7/15/2022. (zcal) (Entered: 05/24/2022)
2022-07-1517Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Valdez, Darrell) (Entered: 07/15/2022)
2022-07-15MINUTE ORDER. Upon review of the 17 Joint Status Report, it is ORDERED that the Parties shall file an updated Joint Status Report on or before September 20, 2022. Signed by Judge Carl J. Nichols on July 15, 2022. (lccjn2) (Entered: 07/15/2022)
2022-07-15Set/Reset Deadlines: Joint Status Report due by 9/20/2022. (zcal) (Entered: 07/19/2022)
2022-08-0418NOTICE OF SUBSTITUTION OF COUNSEL by Kartik Narayan Venguswamy on behalf of FEDERAL BUREAU OF INVESTIGATION Substituting for attorney Darrell C. Valdez (Venguswamy, Kartik) (Entered: 08/04/2022)
2022-09-2019Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Venguswamy, Kartik) (Entered: 09/20/2022)
2022-09-26MINUTE ORDER. Upon consideration of the 19 Joint Status Report, it is ORDERED that the Parties shall file an additional joint status report on or before November 23, 2022, and every 60 days thereafter until either party moves for a briefing schedule for dispositive motions, files a dispositive motion, or the case is terminated. Signed by Judge Carl J. Nichols on September 26, 2022. (lccjn2) (Entered: 09/26/2022)
2022-09-26Set/Reset Deadlines: Joint Status Report due by 11/23/2022. (zcal) (Entered: 09/27/2022)
2022-11-1720RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. FEDERAL BUREAU OF INVESTIGATION served on 12/16/2020, RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 12/16/2020., RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 1/26/2021. ( Answer due for ALL FEDERAL DEFENDANTS by 2/25/2021.) (Sorenson, C.) (Entered: 11/17/2022)
2022-11-2321Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Venguswamy, Kartik) (Entered: 11/23/2022)
2023-01-0322MOTION for Order Establish Rate of Production by GLOBAL HEALTH PROMISE. (Attachments: # 1 Declaration Willis, # 2 Exhibit 101, # 3 Exhibit 102, # 4 Exhibit 103, # 5 Exhibit 104, # 6 Memorandum in Support, # 7 Text of Proposed Order)(Sorenson, C.) (Entered: 01/03/2023)
2023-01-1423Consent MOTION for Extension of Time to File Response/Reply as to 22 MOTION for Order Establish Rate of Production by FEDERAL BUREAU OF INVESTIGATION. (Venguswamy, Kartik) (Entered: 01/14/2023)
2023-01-19MINUTE ORDER. Upon review of Defendant's 23 Consent Motion for Extension of Time, it is ORDERED that the Motion is GRANTED. Defendant shall respond to Plaintiff's 22 Motion for Order to Establish Rate of Production on or before March 20, 2023, and Plaintiff shall file a reply, if any, on or before April 17, 2023. Signed by Judge Carl J. Nichols on January 19, 2023. (lccjn2) (Entered: 01/19/2023)
2023-01-2324Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Venguswamy, Kartik) (Entered: 01/23/2023)
2023-03-1625Consent MOTION for Extension of Time to File Response/Reply as to 22 MOTION for Order Establish Rate of Production by FEDERAL BUREAU OF INVESTIGATION. (Venguswamy, Kartik) (Entered: 03/16/2023)
2023-04-0426Consent MOTION for Extension of Time to File Response/Reply as to 22 MOTION for Order Establish Rate of Production by FEDERAL BUREAU OF INVESTIGATION. (Venguswamy, Kartik) (Entered: 04/04/2023)
2023-04-05MINUTE ORDER. Upon review of the 26 Consent Motion for Extension of Time, it is ORDERED that the Motion is GRANTED nunc pro tunc . Defendant shall respond to Plaintiff's 22 Motion for Order to Establish Rate of Production on or before April 7, 2023, and Plaintiff shall file a reply, if any, on or before May 10, 2023. Signed by Judge Carl J. Nichols on April 5, 2023. (lccjn2) (Entered: 04/05/2023)
2023-04-0827Memorandum in opposition to re 22 Motion for Order, filed by FEDERAL BUREAU OF INVESTIGATION. (Attachments: # 1 Declaration Bender Declaration, # 2 Exhibit Exhibits A-K, # 3 Exhibit Exhibits L-S, # 4 Exhibit Exhibits T-Y)(Venguswamy, Kartik) (Entered: 04/08/2023)
2023-04-2428Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Venguswamy, Kartik) (Entered: 04/24/2023)
2023-05-0929REPLY to opposition to motion re 22 MOTION for Order Establish Rate of Production filed by GLOBAL HEALTH PROMISE. (Sorenson, C.) (Entered: 05/09/2023)
2023-07-2430Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Venguswamy, Kartik) (Entered: 07/24/2023)
2023-09-13MINUTE ORDER. Upon review of Plaintiff's 22 Motion to Establish Rate of Production, it is ORDERED that the Motion is DENIED. The parties are, however, encouraged to meet and confer about whether the FBI should prioritize processing certain categories of documents. Signed by Judge Carl J. Nichols on September 13, 2023. (lccjn2) (Entered: 09/13/2023)
2023-10-2431Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Venguswamy, Kartik) (Entered: 10/24/2023)
2023-12-1932Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Venguswamy, Kartik) (Entered: 12/19/2023)
2024-02-2033Joint STATUS REPORT by FEDERAL BUREAU OF INVESTIGATION. (Venguswamy, Kartik) (Entered: 02/20/2024)
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