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Case TitleLOUISE TRAUMA CENTER LLC v. UNITED STATES DEPARTMENT OF JUSTICE
DistrictDistrict of Columbia
CityWashington, DC
Case Number1:2022cv02287
Date Filed2022-08-03
Date ClosedOpen
JudgeJudge Randolph D. Moss
PlaintiffLOUISE TRAUMA CENTER LLC
Case DescriptionThe Louise Trauma Center submitted two FOIA requests to the Department of Justice for records concerning money paid to Brian Fitzpatrick for the research and preparation of the Fitzpatrick Matrix. The agency acknowledged receipt of the requests but after hearing nothing further from the agency, the Louise Trauma Center filed suit.
Complaint issues: Failure to respond within statutory time limit, Litigation - Attorney's fees

DefendantUNITED STATES DEPARTMENT OF JUSTICE
Documents
Docket
Complaint
Complaint attachment 1
Complaint attachment 2
Complaint attachment 3
Complaint attachment 4
User-contributed Documents
 
Docket Events (Hide)
Date FiledDoc #Docket Text

2022-08-031COMPLAINT against UNITED STATES DEPARTMENT OF JUSTICE ( Filing fee $ 402 receipt number ADCDC-9414976) filed by LOUISE TRAUMA CENTER LLC. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons)(Cleveland, David) (Entered: 08/03/2022)
2022-08-03Case Assigned to Judge Randolph D. Moss. (zsb) (Entered: 08/03/2022)
2022-08-032STANDING ORDER: The parties are hereby ORDERED to comply with the directives set forth in the attached Standing Order. See document for details. Signed by Judge Randolph D. Moss on 08/03/2022. (lcrdm3) (Entered: 08/03/2022)
2022-08-053REQUEST FOR SUMMONS TO ISSUE re 1 Complaint, filed by LOUISE TRAUMA CENTER LLC. Related document: 1 Complaint, filed by LOUISE TRAUMA CENTER LLC.(Cleveland, David) (Entered: 08/05/2022)
2022-08-054SUMMONS (3) Issued Electronically as to UNITED STATES DEPARTMENT OF JUSTICE, U.S. Attorney and U.S. Attorney General (Attachment: # 1 Notice and Consent)(zmrl) (Entered: 08/05/2022)
2022-08-105RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 8/10/2022. Answer due for ALL FEDERAL DEFENDANTS by 9/9/2022. (Cleveland, David) (Entered: 08/10/2022)
2022-08-126RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 08/12/2022. (Attachments: # 1 Exhibit)(Cleveland, David) (Entered: 08/12/2022)
2022-08-167RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. UNITED STATES DEPARTMENT OF JUSTICE served on 8/15/2022 (Attachments: # 1 Exhibit)(Cleveland, David) (Entered: 08/16/2022)
2022-08-308NOTICE of Appearance by Robert Aaron Caplen on behalf of UNITED STATES DEPARTMENT OF JUSTICE (Caplen, Robert) (Entered: 08/30/2022)
2022-08-309Consent MOTION for Extension of Time to File Answer re 1 Complaint, by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order)(Caplen, Robert) (Entered: 08/30/2022)
2022-08-31MINUTE ORDER: Upon consideration of Defendant's consent motion for extension of time, Dkt. 9 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Defendant shall file a responsive pleading on or before October 27, 2022. Signed by Judge Randolph D. Moss on 08/31/2022. (lcrdm3) (Entered: 08/31/2022)
2022-10-2410Consent MOTION for Extension of Time to File Answer re 1 Complaint, by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order)(Caplen, Robert) (Entered: 10/24/2022)
2022-10-24MINUTE ORDER: Upon consideration of Defendant's consent motion for extension of time, Dkt. 10 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Defendant shall file a responsive pleading on or before November 3, 2022. Signed by Judge Randolph D. Moss on 10/24/2022. (lcrdm3) (Entered: 10/24/2022)
2022-11-0311ANSWER to Complaint by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Caplen, Robert) (Entered: 11/03/2022)
2022-11-03MINUTE ORDER: It is ORDERED that, on or before December 7, 2022, the parties shall confer and file a joint status report addressing (1) any documents still to be produced pursuant to FOIA; (2) an anticipated schedule for processing and producing any such documents; and (3) any substantive areas of disagreement between the parties. It is further ORDERED that the parties shall appear by video for an Initial Scheduling Conference on December 14, 2022, at 10:00 a.m., before Judge Randolph D. Moss. Signed by Judge Randolph D. Moss on 11/3/2022. (lcrdm3) (Entered: 11/03/2022)
2022-12-0712Joint STATUS REPORT by UNITED STATES DEPARTMENT OF JUSTICE. (Caplen, Robert) (Entered: 12/07/2022)
2022-12-14Minute Entry for proceedings held before Judge Randolph D. Moss: Video (Zoom) Initial Scheduling Conference held on 12/14/2022. For the reasons stated on the record, count two of the complaint is dismissed; As to count one, Defendant shall process 500 pages per month; As to count 4, Defendant shall produce the documents at issue on or before 2/10/2023. The parties shall file a Joint Status Report by 3/3/2023 to address all remaining issues. (Court Reporter: Jeff Hook.) (kt) (Entered: 12/14/2022)
2023-02-0113NOTICE OF SUBSTITUTION OF COUNSEL by Brian J. Levy on behalf of UNITED STATES DEPARTMENT OF JUSTICE Substituting for attorney Robert A. Caplen (Levy, Brian) (Entered: 02/01/2023)
2023-03-0314Joint STATUS REPORT by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order)(Levy, Brian) (Entered: 03/03/2023)
2023-03-03MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 14 , it is hereby ORDERED that the parties shall file a further joint status report on or before May 5, 2023. Signed by Judge Randolph D. Moss on 3/3/2023.(lcrdm3) (Entered: 03/03/2023)
2023-05-0315Joint STATUS REPORT by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order Defendant's Proposed Order, # 2 Text of Proposed Order Plaintiff's Proposed Order)(Levy, Brian) (Entered: 05/03/2023)
2023-05-03MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 15 , it is hereby ORDERED that the parties shall file a further joint status report on or before May 31, 2023. To the extent that Plaintiff wishes to file a motion for summary judgment, Plaintiff shall refer to the procedures for doing so as set forth in the Court's Standing Order, Dkt. 2 at 4. Signed by Judge Randolph D. Moss on 5/3/2023. (lcrdm3) (Entered: 05/03/2023)
2023-05-3016STATUS REPORT by LOUISE TRAUMA CENTER LLC. (Cleveland, David) (Entered: 05/30/2023)
2023-05-3117STATUS REPORT by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order)(Levy, Brian) (Entered: 05/31/2023)
2023-06-15MINUTE ORDER: Upon consideration of the parties' status reports, Dkt. 16 , Dkt. 17 , it is hereby ORDERED that the parties shall, after meeting and conferring, file a further joint status report on or before June 30, 2023. Signed by Judge Randolph D. Moss on 6/15/2023. (lcrdm3) (Entered: 06/15/2023)
2023-06-3018Joint STATUS REPORT by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order Plaintiff's Proposed Order, # 2 Text of Proposed Order Defendant's Proposed Order)(Levy, Brian) (Entered: 06/30/2023)
2023-07-02MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 18 , it is hereby ORDERED that the parties shall file a further joint status report on or before July 31, 2023. If the government has not yet completed its re-review by then, the government shall, in its joint status report, detail (1) precisely what steps it has taken; (2) what steps, if any remain; and (3) a firm date by which its re-review will be completed. Signed by Judge Randolph D. Moss on 7/2/2023. (lcrdm3) (Entered: 07/02/2023)
2023-07-3119Joint STATUS REPORT by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order Plaintiff's [Proposed] Order, # 2 Text of Proposed Order Defendant's [Proposed] Order)(Levy, Brian) (Entered: 07/31/2023)
2023-08-02MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 19 , it is hereby ORDERED that the parties shall submit a further joint status report on or before September 1, 2023. The status report should describe any outstanding issues and propose a briefing schedule for summary judgment, if any such issues remain. Signed by Judge Randolph D. Moss on 08/02/2023. (lcrdm3) (Entered: 08/02/2023)
2023-09-0120Joint STATUS REPORT by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order Defendant's Proposed Order, # 2 Text of Proposed Order Plaintiff's Proposed Order)(Levy, Brian) (Entered: 09/01/2023)
2023-09-04MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 20 , it is hereby ORDERED that: (1) Defendant shall submit a draft Vaughn index and search declaration to Plaintiff on or before October 24, 2023; (2) Defendant shall file its pre-motion statement with the Court on or before October 24, 2023; and (3) Plaintiff shall file its pre-motion statement with the Court on or before October 31, 2023. Signed by Judge Randolph D. Moss on 09/04/2023. (lcrdm3) (Entered: 09/04/2023)
2023-10-2421MOTION to Modify Briefing Schedule by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order)(Levy, Brian) (Entered: 10/24/2023)
2023-10-2422NOTICE Pre-Motion Statement by UNITED STATES DEPARTMENT OF JUSTICE (Levy, Brian) (Entered: 10/24/2023)
2023-10-26MINUTE ORDER: Upon consideration of Defendant's motion to modify the briefing schedule, Dkt. 21 , it is hereby ORDERED that: (1) Defendant shall submit a draft Vaughn index and search declaration to Plaintiff on or before October 31, 2023, and (2) Plaintiff shall file its pre-motion statement with the Court on or before November 7, 2023. Signed by Judge Randolph D. Moss on 10/26/2023. (lcrdm3) (Entered: 10/26/2023)
2023-11-0523NOTICE of Pre Motion Statement filed by LOUISE TRAUMA CENTER LLC. (Cleveland, David) Modified on 11/7/2023 to correct event/docket text (zjm). (Entered: 11/05/2023)
2023-11-07MINUTE ORDER: In light of section 10(a) of the Court's Standing Order, see Dkt. 2 at 4, the Court finds that a pre-motion conference is appropriate. Accordingly, it is hereby ORDERED that the parties shall appear on November 29, 2023, at 2:00 p.m., in Courtroom 8. Signed by Judge Randolph D. Moss on 11/7/20. (lcrdm3) (Entered: 11/07/2023)
2023-11-1324MOTION to Vacate and Reschedule Hearing by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order)(Levy, Brian) (Entered: 11/13/2023)
2023-11-14MINUTE ORDER: Upon consideration of Defendant's motion to reschedule, Dkt. 24 , it is hereby ORDERED that the motions hearing scheduled for November 29, 2023, is VACATED. The Court will reschedule the hearing once the parties have conferred with the Court's deputy clerk regarding their availability. Signed by Judge Randolph D. Moss on 11/14/2023. (lcrdm3) (Entered: 11/14/2023)
2023-11-27NOTICE of Hearing:Pre-Motion Conference set for 12/19/2023 at 10:00 AM in Courtroom 8- In Person before Judge Randolph D. Moss.(zglw) (Entered: 11/27/2023)
2023-12-11MINUTE ORDER: In light of a scheduling conflict, the pre-motion conference currently scheduled for December 19, 2023 is hereby VACATED. The Court will reschedule the hearing once the parties have conferred with the Court's deputy clerk regarding their availability. Signed by Judge Randolph D. Moss on 12/11/2023. (lcrdm3) (Entered: 12/11/2023)
2023-12-18Set/Reset Hearings: Pre-motion Conference set for 2/1/2024 at 03:00 PM in Courtroom 8- In Person before Judge Randolph D. Moss. (zglw) (Entered: 12/18/2023)
2024-02-01Minute Entry for proceedings held before Judge Randolph D. Moss: Pre-motion Conference held on 2/1/2024. Defendant to file Motion by 3/14/2024. Plaintiff's Response/Cross Motion due by 3/21/2024. Defendant's reply due by 4/11/2024 and Plaintiff's final reply due by 4/18/2024. (Court Reporter Tammi Sefranek) (zglw) (Entered: 02/01/2024)
2024-03-1125MOTION to Modify the Briefing Schedule by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order)(Levy, Brian) (Entered: 03/11/2024)
2024-03-13MINUTE ORDER: Upon consideration of Defendant's motion to modify briefing schedule, Dkt. 25 , it is hereby ORDERED that Plaintiff shall indicate whether or not it opposes the motion on or before March 14, 2024 at 12:00 p.m. Signed by Judge Randolph D. Moss on 3/13/2024. (lcrdm3) (Entered: 03/13/2024)
2024-03-1326RESPONSE re 25 MOTION to Modify the Briefing Schedule filed by LOUISE TRAUMA CENTER LLC. (Cleveland, David) (Entered: 03/13/2024)
2024-03-14MINUTE ORDER: Upon consideration of Defendant's motion to modify the briefing schedule, Dkt. 25 , and Plaintiff's response thereto, Dkt. 26 , indicating that it partially consents to the requested extension, it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that: (1) Defendant's motion for summary judgment shall be filed on or before March 28; (2) Plaintiff's opposition and cross-motion for summary judgment shall be filed on or before April 4; (3) Defendant's reply in support of its motion for summary judgment and opposition to Plaintiff's motion shall be filed on or before April 25; and (4) Plaintiff's reply in support of its cross-motion shall be due on or before May 2. Signed by Judge Randolph D. Moss on 3/14/2024. (lcrdm3) (Entered: 03/14/2024)
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