| Date Filed | Doc # | Docket Text |
|
| 2012-07-30 | 1 | COMPLAINT against United States Department of Homeland Security. (Filing Fee $ 350.00, Receipt Number 1045012)Document filed by Adam Conti. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3)(tro) (Entered: 08/03/2012) |
| 2012-07-30 | | SUMMONS ISSUED as to United States Department of Homeland Security, U.S. Attorney and U.S. Attorney General. (tro) (Entered: 08/03/2012) |
| 2012-07-30 | | Magistrate Judge Ronald L. Ellis is so designated. (tro) (Entered: 08/03/2012) |
| 2012-07-30 | | Case Designated ECF. (tro) (Entered: 08/03/2012) |
| 2012-08-08 | 2 | ORDER AND NOTICE OF INITIAL CONFERENCE: Counsel for all parties shall appear for an initial status conference set for 10/11/2012 at 10:30 AM in Courtroom 9B of the U.S. Courthouse for the Southern District of New York, 500 Pearl Street, New York, NY 10007 before Judge Ronnie Abrams. By 10/4/2012, the parties shall submit a joint letter, not to exceed 5 pages, provided the information in separate paragraphs as further set forth in this Order. By 10/4/2012, the parties shall jointly submit to the Court a proposed case management plan and scheduling order. Plaintiff is ordered to serve Defendants with a copy of this order and to file an affidavit on ECF certifying that such service has been effectuated. (Signed by Judge Ronnie Abrams on 8/8/2012) (tro) Modified on 8/8/2012 (tro). (Entered: 08/08/2012) |
| 2012-09-24 | | Set/Reset Hearings: Initial Conference re-scheduled for 10/10/2012 at 10:45 AM in Courtroom 9B, 500 Pearl Street, New York, NY 10007 before Judge Ronnie Abrams, with the consent of plaintiff's counsel, Mr. Jeffrey Pollock. (arc) Modified on 9/24/2012 (arc). (Entered: 09/24/2012) |
| 2012-10-01 | 3 | NOTICE OF APPEARANCE by Rebecca Sol Tinio on behalf of United States Department of Homeland Security (Tinio, Rebecca) (Entered: 10/01/2012) |
| 2012-10-02 | 4 | ENDORSED LETTER addressed to Judge Ronnie Abrams from Jeffrey M. Pollock dated 9/25/2012 re: Counsel respectfully requests that the status conference be rescheduled to some time in November. ENDORSEMENT: Application granted. The initial conference is rescheduled for November 15, 2012 at 3:00 p.m. ( Initial Conference set for 11/15/2012 at 03:00 PM before Judge Ronnie Abrams.) (Signed by Judge Ronnie Abrams on 10/2/2012) (jfe) Modified on 10/3/2012 (jfe). (Entered: 10/02/2012) |
| 2012-11-13 | 5 | ENDORSED LETTER addressed to Judge Ronnie Abrams from Rebecca S. Tinio dated 11/13/2012 re: I write respectfully to request an adjournment of the initial conference scheduled in this case for November 15, 2012, at 3 p.m., to a date in December 2012 or later that is convenient for the Court. ENDORSEMENT: Application granted. The initial conference is rescheduled for December 19, 2012 at 11:45 a.m. SO ORDERED., ( Initial Conference set for 12/19/2012 at 11:45 AM before Judge Ronnie Abrams.) (Signed by Judge Ronnie Abrams on 11/13/2012) (ama) (Entered: 11/13/2012) |
| 2012-11-13 | 6 | NOTICE OF APPEARANCE by Joel M. Ferdinand on behalf of Adam Conti (Ferdinand, Joel) (Entered: 11/13/2012) |
| 2012-11-16 | 7 | ENDORSED LETTER addressed to Judge Ronnie Abrams from Joel M. Ferdinand dated 11/16/2012 re: Counsel requests that the status conference be rescheduled to D December 20, 2012 at 10:00 a.m. ENDORSEMENT: So Ordered. (Signed by Judge Ronnie Abrams on 11/16/2012) (js) (Entered: 11/19/2012) |
| 2012-11-26 | 8 | NOTICE of Certification of Service of Order and Notice of Initial Conference re: 2 Order, Set Hearings,,,,,,. Document filed by Adam Conti. (Ferdinand, Joel) (Entered: 11/26/2012) |
| 2012-11-30 | 9 | ANSWER to 1 Complaint. Document filed by United States Department of Homeland Security.(Tinio, Rebecca) (Entered: 11/30/2012) |
| 2012-12-20 | | Minute Entry for proceedings held before Judge Ronnie Abrams: Initial Pretrial Conference held on 12/20/2012. (arc) (Entered: 12/20/2012) |
| 2012-12-20 | 10 | STIPULATION AND ORDER: The Government will process and release non-exempt records that are responsive to Plaintiffs April 12, 2011 FOIA request on a rolling basis, and will complete its production of non-exempt, responsive records to Plaintiff no later than February 28, 2013. The Government will notify Plaintiff when it has completed its production. The date on which Plaintiff receives such notification will be referred to as the "completion date." Following Plaintiffs receipt of the Vaughn index, the parties will discuss and attempt to resolve any challenges that Plaintiff raises to the exemptions asserted by the Government. Within 30 days of Plaintiffs receipt of the Vaughn index, Plaintiff will, after conferring with the Government, (1) move to dismiss his complaint with prejudice; (2) propose to the Court a briefing schedule for cross-motions for summary judgment; or (3) advise the Court of his desire to take written and/or deposition discovery. (Signed by Judge Ronnie Abrams on 12/20/2012) (ft) (Entered: 12/20/2012) |
| 2013-02-04 | | Please be advised that Judge Abrams Courtroom and Chambers have been moved to the Thurgood Marshall United States Courthouse located at 40 Foley Square, New York, New York 10007. Effective immediately, all proceedings before the Court will take place in Courtroom 1506, and the Courts Chambers located in Room 2203, of 40 Foley Square. The Courts other contact information, as set forth in the Courts Individual Rules and Practices, available at http://www.nysd.uscourts.gov/judge/Abrams, remains the same.(arc) (Entered: 02/04/2013) |
| 2013-02-26 | 11 | REVISED SCHEDULING ORDER: The Government will process and release non-exempt records that are responsive to Plaintiff's April 12, 2011 FOIA request on a rolling basis, and will complete its production of non-exempt, responsive records to Plaintiff no later than March 25, 2013. No further extensions of this date will be granted absent good cause. The Government will notify Plaintiff when it has completed its production. The date on which Plaintiff receives such notification will be referred to as the "completion date." Following Plaintiff's receipt of the Vaughn index, the parties will discuss and attempt to resolve any challenges that Plaintiff raises to the exemptions asserted by the Government. Within 30 days of Plaintiff's receipt of the Vaughn index, Plaintiff will, after conferring with the Government, (1) move to dismiss his complaint with prejudice; (2) propose to the Court a briefing schedule for cross-motions for summary judgment; or (3) advise the Court of his desire to take written and/or deposition discovery. (Signed by Judge Ronnie Abrams on 2/26/2013) (ft) (Entered: 02/26/2013) |
| 2013-05-20 | 12 | ENDORSED LETTER addressed to Judge Ronnie Abrams from Rebecca S. Tinio dated 5/16/2013 re: We request a short extension of the Government's deadline pursuant to the Revised Stipulation and Order filed February 26, 2013, to produce a "Vaughn" index to Plaintiff. ENDORSEMENT: Application granted. (Signed by Judge Ronnie Abrams on 5/20/2013) (cd) (Entered: 05/20/2013) |
| 2013-05-23 | 13 | NOTICE OF CASE REASSIGNMENT to Judge Analisa Torres. Judge Ronnie Abrams is no longer assigned to the case. (pgu) (Entered: 05/23/2013) |
| 2013-06-24 | 14 | NOTICE OF CHANGE OF ADDRESS by Joel M. Ferdinand on behalf of Adam Conti. New Address: FisherBroyles, LLP, 1200 Abernathy Road, Building 600, Suite 1700, Atlanta, GA, USA 30328, 4049732180. (Ferdinand, Joel) (Entered: 06/24/2013) |
| 2013-06-27 | 15 | ORDER: As counsel may be aware, this case was recently transferred to me. My Individual Practices in Civil Cases are available at http://www.nysd.uscourts.gov/judge/Torres. All current deadlines and schedules remain in effect, unless otherwise directed by the Court. The parties are reminded that motion practice is governed by Paragraph III.A-C of thisCourt's Individual Practices in Civil Cases. A pre-motion conference is required prior to the filing of a motion. The deadline for requesting a pre-motion conference in this matter is July 1, 2013. SO ORDERED. (Signed by Judge Analisa Torres on 6/26/2013) (rsh) (Entered: 06/27/2013) |
| 2013-08-05 | 16 | LETTER addressed to Judge Analisa Torres from Joel M. Ferdinand dated 7/1/2013 re: This law firm represents plaintiff, Adam Conti, in the above- referenced action, and writes pursuant to paragraph 5 of the Courts February 26, 2013 Revised Scheduling Order to advise that Mr. Conti desires to take deposition discovery. Mr. Conti respectfully requests that a schedule for deposition discovery be ordered to ascertain, inter alia, the questioned adequacy of DHS search for responsive documents. Document filed by Adam Conti. (rsh) (Entered: 08/05/2013) |
| 2013-08-05 | 17 | LETTER addressed to Judge Analisa Torres from Rebecca S. Tinio dated 7/24/2013 re: This Office represents the United States Department of Homeland Security (DHS), the Defendant in the above-captioned FOIA litigation. This letter, submitted jointly with counsel for the Plaintiff pursuant to the Local Rules and to the Courts Individual Practices, serves to alert the Court to a discovery dispute in this matter. By way of clarification, the dispute referenced in this letter is the same issue discussed in the parties letters to the Court dated July 1 and July 10, 2013. The parties submit this letter out of an abundance of caution, to represent to the Court that they have complied with the Local Rules and the Courts Individual Practices relating to discovery disputes. The parties believe thatthe matters discussed herein and in the parties previous letters may be addressed in one conference before the Court, at the Courts convenience. Document filed by United States Department of Homeland Security.(rsh) (Entered: 08/05/2013) |
| 2013-08-05 | 18 | ORDER: The Court having reviewed: (1) Plaintiffs letters dated July 1 and 10,2013, (2) Defendant's July 24, 2013 letter and (3) Plaintiff and Defendant's July 24, 2013 joint letter, it is ORDERED that: 1. Plaintiffs request for deposition discovery is DENIED as premature. Challenges to a government agency's FOIA response are generally resolved on a motion for summary judgment. New York Times Co. v. US. Department of Justice, 915 F. Supp. 2d 508, 531 (S.D.N.Y. 2013). 2. Defendant's request for a forty-five day extension to respond to issues and objections raised by Plaintiff regarding Defendant's document production is GRANTED. Defendant shall complete its investigation by August 22, 2013. No further extensions will be granted. 3. If the parties are unable to resolve issues regarding document production by August 22, 2013, the following motion schedule shall apply: a. Motion for summary judgment is due September 5, 2013; b. Opposition papers are due September 19, 2013; and c. Reply papers are due September 26, 2013. 4. Defendant shall submit with its motion papers affidavits or declarations to support a showing that Defendant's search was adequate and that any withheld documents fall within an exemption to the FOIA. Carney v. US. Dept. of Justice, 19 F. 3d 807, 812 (1994). Plaintiff shall respond by making a showing of "bad faith on the part of the agency sufficient to impugn the agency's affidavits or declarations... or provide some tangible evidence that an exemption claimed by an agency should not apply or summary judgment is otherwise inappropriate." Id. (citations omitted). SO ORDERED. (Motions due by 9/5/2013., Responses due by 9/19/2013, Replies due by 9/26/2013.) (Signed by Judge Analisa Torres on 8/2/2013) (rsh) (Entered: 08/05/2013) |
| 2013-09-03 | 19 | ORDER: The Court having received Defendant and Plaintiff's letters dated September 3, 2013, regarding Defendant's request for an extension to file its motion for summary judgment and Plaintiff's response objecting to the extension, it is ORDERED that: Defendant shall file its motion for summary judgment by September 11, 2013; Plaintiff shall file his opposition papers by September 25, 2013; and Defendant shall file its reply papers by October 2, 2013. (Motions due by 9/11/2013., Responses due by 9/25/2013, Replies due by 10/2/2013.) (Signed by Judge Analisa Torres on 9/3/2013) (rsh) (Entered: 09/03/2013) |
| 2013-09-11 | 20 | MOTION for Summary Judgment. Document filed by United States Department of Homeland Security.(Tinio, Rebecca) (Entered: 09/11/2013) |
| 2013-09-11 | 21 | MEMORANDUM OF LAW in Support re: 20 MOTION for Summary Judgment.. Document filed by United States Department of Homeland Security. (Tinio, Rebecca) (Entered: 09/11/2013) |
| 2013-09-11 | 22 | DECLARATION of Stephanie L. Kuehn in Support re: 20 MOTION for Summary Judgment.. Document filed by United States Department of Homeland Security. (Attachments: # 1 Declaration of Stephanie L. Kuehn, Pt. 2)(Tinio, Rebecca) (Entered: 09/11/2013) |
| 2013-09-11 | 23 | DECLARATION of Rebecca S. Tinio in Support re: 20 MOTION for Summary Judgment.. Document filed by United States Department of Homeland Security. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3)(Tinio, Rebecca) (Entered: 09/11/2013) |
| 2013-09-11 | 24 | DECLARATION of Ryan Law in Support re: 20 MOTION for Summary Judgment.. Document filed by United States Department of Homeland Security. (Attachments: # 1 Declaration of Ryan Law Pt. 2, # 2 Exhibit 1A-1B, # 3 Exhibit 1C-1D, # 4 Exhibit 1E, # 5 Exhibit 1F, # 6 Exhibit 2-6, # 7 Exhibit 7-9, # 8 Exhibit 10-16)(Tinio, Rebecca) (Entered: 09/11/2013) |
| 2013-09-19 | 25 | ORDER: The Court having received Plaintiffs letter dated September 19, 2013, in which both parties request an extension of the briefing schedule, it is ORDERED that: Plaintiff shall file his opposition papers and any cross motion papers by October 9, 2013; and Defendant shall file its reply and opposition papers by November 6, 2013. (Cross Motions due by 10/9/2013., Responses due by 11/6/2013, Replies due by 11/6/2013.) (Signed by Judge Analisa Torres on 9/19/2013) (rsh) (Entered: 09/19/2013) |
| 2013-10-01 | 26 | STANDING ORDER M10-468: Stay of Certain Civil Cases Pending the Restoration of Department of Justice Funding. (Signed by Judge Loretta A. Preska on 10/1/2013) ***Original Standing Order docketed in case no. 1:13-mc-00334-LAP, document no. 2 on 10/1/2013.***(tro) (Entered: 10/01/2013) |
| 2013-10-21 | 27 | The Court confirms that the briefing schedule was tolled for a period of sixteen days. Accordingly, Plaintiff's summary judgment opposition brief is due on October 25, 2013 and Defendant's reply brief is due November 22, 2013.(Responses due by October 25, 2013, Replies due by November 22, 2013). (Signed by Judge Analisa Torres on October 21, 2013). (Torres, Analisa) (Entered: 10/21/2013) |
| 2013-10-21 | 28 | LETTER addressed to Judge Analisa Torres from Joel M. Ferdinand dated 10/18/2013 re: This law firm represents plaintiff, Adam Conti, in the above- referenced action. Based on the October 1, 2013 Order staying this action and tolling all briefing schedules for the period of time equal to the number of calendar days between October 1, 2013 and the date the President signed into law a budget appropriation that restored the Department of Justice funding, (a) Mr. Contis summary judgment opposition brief is due on October 25, 2013 (previously due October 9, 2013) and (b) DHS reply brief is due on November 22, 2013 (previously due on November 6, 2013). Document filed by Adam Conti.(rsh) (Entered: 10/21/2013) |
| 2013-10-25 | 29 | FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - MEMORANDUM OF LAW in Opposition re: 20 MOTION for Summary Judgment. and Cross Motion to compel limited discovery, or, in the alternative, for an in camera review, or in the alternative, for attorneys' fees, costs, and expenses . Document filed by Adam Conti. (Attachments: # 1 Memorandum of Law in Opposition to Defendant's Summary Judgment Motion and In Support of Plaintiff's motion to compel discovery, or in the alternative, for an in camera review, or in the alternative for reasonable attorneys' fees, costs and expenses, # 2 Affidavit Declaration of Adam Conti with Exhibits, # 3 Affidavit Declaration of Counsel, Joel M. Ferdinand, Esq., # 4 Exhibit A to Declaration of Counsel, # 5 Exhibit B to Declaration of Counsel, # 6 Exhibit C to Declaration of Counsel, # 7 Exhibit D, part 1, to Declaration of Counsel, # 8 Exhibit D, part 2, to Declaration of Counsel, # 9 Exhibit D, part 3, to Declaration of Counsel, # 10 Exhibit D, part 4, to Declaration of Counsel, # 11 Exhibit E to Declaration of Counsel, # 12 Exhibit F to Declaration of Counsel, # 13 Exhibit G to Declaration of Counsel, # 14 Exhibit H to Declaration of Counsel, # 15 Exhibit I(1) to Declaration of Counsel, # 16 Exhibit I(2) to Declaration of Counsel, # 17 Exhibit I(3) to Declaration of Counsel, # 18 Exhibit J to Declaration of Counsel, # 19 Exhibit K, part 1, to Declaration of Counsel, # 20 Exhibit K, part 2, to Declaration of Counsel, # 21 Exhibit L to Declaration of Counsel, # 22 Exhibit M to Declaration of Counsel, # 23 Exhibit N to Declaration of Counsel, # 24 Exhibit O to Declaration of Counsel, # 25 Text of Proposed Order Proposed form of Order granting cross motion to compel limited discovery, # 26 Text of Proposed Order Proposed form of Order granting cross motion for an in camera review, # 27 Text of Proposed Order Proposed form of Order granting cross motion for attorneys' fees, costs, and expenses, # 28 Affidavit Certification of Filing and Service)(Ferdinand, Joel) Modified on 10/28/2013 (db). (Entered: 10/25/2013) |
| 2013-10-28 | | ***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - EVENT TYPE ERROR. Note to Attorney Joel M. Ferdinand to (1) RE-FILE Document 29 Memorandum of Law in Opposition to Motion. Use the event type Compel found under the event list Motions. (2) File all Supporting and/or Opposing Documents separately using the Event Types found under - Replies, Opposition and Supporting Documents. 3 Documents to be refiled: (1) Motion (with proposed order and certificate of service attached); (2) Memorandum in Support of Motion; and (3) Declaration in Support of Motion (with attached exhibits). (db) (Entered: 10/28/2013) |
| 2013-10-29 | 30 | FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - MOTION to Compel United States Department of Homeland Security to Produce documents, or, in the alternative, for an In Camera Inspection, or, in the alternative, for Attorneys' Fees, Costs, and Expenses. Document filed by Adam Conti. (Attachments: # 1 Notice of Cross Motion to Compel, or, in the alternative, for an In Camera Review, or, in the alternative, for Attorneys' Fees, Costs, and Expenses, # 2 Declaration of Adam Conti with Exhibits, # 3 Declaration of Counsel, Joel M. Ferdinand, Esq., # 4 Exhibit A to the Declaration of Counsel, # 5 Exhibit B to the Declaration of Counsel, # 6 Exhibit C to the Declaration of Counsel, # 7 Exhibit D, part 1, to the Declaration of Counsel, # 8 Exhibit D, part 2, to the Declaration of Counsel, # 9 Exhibit D, part 3, to the Declaration of Counsel, # 10 Exhibit D, part 4, to the Declaration of Counsel, # 11 Exhibit E to the Declaration of Counsel, # 12 Exhibit F to the Declaration of Counsel, # 13 Exhibit G to the Declaration of Counsel, # 14 Exhibit H to the Declaration of Counsel, # 15 Exhibit I(1) to the Declaration of Counsel, # 16 Exhibit I(2) to the Declaration of Counsel, # 17 Exhibit I(3) to the Declaration of Counsel, # 18 Exhibit J to the Declaration of Counsel, # 19 Exhibit K, part 1, to the Declaration of Counsel, # 20 Exhibit K, part 2, to the Declaration of Counsel, # 21 Exhibit L to the Declaration of Counsel, # 22 Exhibit M to the Declaration of Counsel, # 23 Exhibit N to the Declaration of Counsel, # 24 Exhibit O to the Declaration of Counsel, # 25 Text of Proposed Order Proposed Form of Order Granting Cross Motion to Compel, # 26 Text of Proposed Order Proposed Form of Order Granting Cross Motion for an In Camera Review, # 27 Text of Proposed Order Proposed Form of Order Granting Attorneys' Fees, Costs, and Expenses, # 28 Certifiation of Filing and Service)(Ferdinand, Joel) Modified on 10/30/2013 (db). (Entered: 10/29/2013) |
| 2013-10-29 | 31 | MEMORANDUM OF LAW in Opposition re: 20 MOTION for Summary Judgment.. Document filed by Adam Conti. (Attachments: # 1 Declaration of Adam Conti with Exhibits, # 2 Declaration of Counsel, Joel M. Ferdinand, Esq., # 3 A to the Declaration of Counsel, # 4 B to the Declaration of Counsel, # 5 C to the Declaration of Counsel, # 6 D, part 1, to the Declaration of Counsel, # 7 D, part 2, to the Declaration of Counsel, # 8 D, part 3, to the Declaration of Counsel, # 9 D, part 4, to the Declaration of Counsel, # 10 E to the Declaration of Counsel, # 11 F to the Declaration of Counsel, # 12 G to the Declaration of Counsel, # 13 H to the Declaration of Counsel, # 14 I(1) to the Declaration of Counsel, # 15 I(2) to the Declaration of Counsel, # 16 I(3) to the Declaration of Counsel, # 17 J to the Declaration of Counsel, # 18 K, part 1, to the Declaration of Counsel, # 19 K, part 2, to the Declaration of Counsel, # 20 L to the Declaration of Counsel, # 21 M to the Declaration of Counsel, # 22 N to the Declaration of Counsel, # 23 O to the Declaration of Counsel, # 24 Text of Proposed Order Proposed Form of Order Denying Summary Judgment and Granting Cross Motion to Compel, # 25 Text of Proposed Order Proposed Form of Order Denying Summary Judgment and Granting Cross Motion for an In Camera Inspection, # 26 Text of Proposed Order Proposed Form of Order Denying Summary Judgment and Granting Cross Motion for Attorneys' Fees, Costs, and Expenses, # 27 Certification of Filing and Service)(Ferdinand, Joel) (Entered: 10/29/2013) |
| 2013-10-29 | 32 | ENDORSED LETTER addressed to Judge Analisa Torres from Joel M. Ferdinand dated 10/25/2013 re: This law firm represents plaintiff, Adam Conti, in the above-referenced action, and writes pursuant to Your Honor's individual practice rules to request oral argument concerning Defendant's motion for summary judgment and plaintiff's cross motion for to compel limited deposition discovery from Defendant, or, in the alternative, for an in camera review of redacted documents in unredacted form, or, in the alternative, for reasonable attorneys' fees, costs, and expenses for Plaintiff's filing and prosecution of this action (Dkt. Entry 29). ENDORSEMENT: The Court will notify counsel if oral argument is required. (Signed by Judge Analisa Torres on 10/29/2013) (rsh) (Entered: 10/29/2013) |
| 2013-10-30 | | ***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - EVENT TYPE ERROR. Note to Attorney Joel M. Ferdinand to RE-FILE Document 30 MOTION to Compel United States Department of Homeland Security to Produce documents, or, in the alternative, for an In Camera Inspection, or, in the alternative, for Attorneys' Fees, Costs, and Expenses. Use the event type Memorandum in Support of Motion found under the event list Replies, Oppostion and Supporting Documents. ***REMINDER*** - Cross Motion to Compel must be filed first. Then file and link any supporting documents (Supporting documents are filed separately, each receiving their own document #. Memorandum in Support of Motion and Declaration in Support of Motion are two different entries). (db) (Entered: 10/30/2013) |
| 2013-10-30 | 33 | MOTION to Compel Defendant, Department of Homeland Security to Produce Documents, or, in the alternative, for an In Camera Review, or, in the alternative, for Attorneys' Fees, Costs, and Expenses . Document filed by Adam Conti.(Ferdinand, Joel) (Entered: 10/30/2013) |
| 2013-10-30 | 34 | MEMORANDUM OF LAW in Support re: 30 MOTION to Compel United States Department of Homeland Security to Produce documents, or, in the alternative, for an In Camera Inspection, or, in the alternative, for Attorneys' Fees, Costs, and Expenses., 33 MOTION to Compel Defendant, Department of Homeland Security to Produce Documents, or, in the alternative, for an In Camera Review, or, in the alternative, for Attorneys' Fees, Costs, and Expenses ., 20 MOTION for Summary Judgment.. Document filed by Adam Conti. (Ferdinand, Joel) (Entered: 10/30/2013) |
| 2013-10-30 | 35 | AFFIDAVIT in Support re: 30 MOTION to Compel United States Department of Homeland Security to Produce documents, or, in the alternative, for an In Camera Inspection, or, in the alternative, for Attorneys' Fees, Costs, and Expenses., 33 MOTION to Compel Defendant, Department of Homeland Security to Produce Documents, or, in the alternative, for an In Camera Review, or, in the alternative, for Attorneys' Fees, Costs, and Expenses ., 20 MOTION for Summary Judgment.. Document filed by Adam Conti. (Ferdinand, Joel) (Entered: 10/30/2013) |
| 2013-10-30 | 36 | AFFIDAVIT in Support re: 33 MOTION to Compel Defendant, Department of Homeland Security to Produce Documents, or, in the alternative, for an In Camera Review, or, in the alternative, for Attorneys' Fees, Costs, and Expenses ., 30 MOTION to Compel United States Department of Homeland Security to Produce documents, or, in the alternative, for an In Camera Inspection, or, in the alternative, for Attorneys' Fees, Costs, and Expenses.. Document filed by Adam Conti. (Attachments: # 1 Exhibit A to the Declaration of Counsel, # 2 Exhibit B to the Declaration of Counsel, # 3 Exhibit C to the Declaration of Counsel, # 4 Exhibit D, part 1, to the Declaration of Counsel, # 5 Exhibit D, part 2, to the Declaration of Counsel, # 6 Exhibit D, part 3, to the Declaration of Counsel, # 7 Exhibit D, part 4, to the Declaration of Counsel, # 8 Exhibit E to the Declaration of Counsel, # 9 Exhibit F to the Declaration of Counsel, # 10 Exhibit G to the Declaration of Counsel, # 11 Exhibit H to the Declaration of Counsel, # 12 Exhibit I(1) to the Declaration of Counsel, # 13 Exhibit I(2) to the Declaration of Counsel, # 14 Exhibit I(3) to the Declaration of Counsel, # 15 Exhibit J to the Declaration of Counsel, # 16 Exhibit K, part 1, to the Declaration of Counsel, # 17 Exhibit K, part 2, to the Declaration of Counsel, # 18 Exhibit L to the Declaration of Counsel, # 19 Exhibit M to the Declaration of Counsel, # 20 Exhibit N to the Declaration of Counsel, # 21 Exhibit O to the Declaration of Counsel)(Ferdinand, Joel) (Entered: 10/30/2013) |
| 2013-10-30 | 37 | DECLARATION in Support re: 30 MOTION to Compel United States Department of Homeland Security to Produce documents, or, in the alternative, for an In Camera Inspection, or, in the alternative, for Attorneys' Fees, Costs, and Expenses., 33 MOTION to Compel Defendant, Department of Homeland Security to Produce Documents, or, in the alternative, for an In Camera Review, or, in the alternative, for Attorneys' Fees, Costs, and Expenses .. Document filed by Adam Conti. (Attachments: # 1 Text of Proposed Order granting cross motion to compel discovery, # 2 Text of Proposed Order granting cross motion for an in camera inspection, # 3 Text of Proposed Order granting cross motion for attorneys' fees, costs, and expenses)(Ferdinand, Joel) (Entered: 10/30/2013) |
| 2013-11-18 | 38 | LETTER MOTION for Extension of Time to File Response/Reply addressed to Judge Analisa Torres from Rebecca S. Tinio dated 11/18/2013. Document filed by United States Department of Homeland Security.(Tinio, Rebecca) (Entered: 11/18/2013) |
| 2013-11-18 | 39 | ORDER granting 38 Letter Motion for Extension of Time to File Response/Reply re 38 LETTER MOTION for Extension of Time to File Response/Reply addressed to Judge Analisa Torres from Rebecca S. Tinio dated 11/18/2013. Defendant's reply is due December 4, 2013. (HEREBY ORDERED by Judge Analisa Torres)(Text Only Order) (Torres, Analisa) (Entered: 11/18/2013) |
| 2013-12-04 | 40 | LETTER MOTION for Extension of Time to File Response/Reply as to 31 Memorandum of Law in Opposition to Motion,,,,,, addressed to Judge Analisa Torres from Rebecca S. Tinio dated 12/4/2013. Document filed by United States Department of Homeland Security.(Tinio, Rebecca) (Entered: 12/04/2013) |
| 2013-12-04 | 41 | ORDER granting 40 Letter Motion for Extension of Time to File Response/Reply. Defendant's reply is due by December 9, 2013. (HEREBY ORDERED by Judge Analisa Torres)(Text Only Order) (Torres, Analisa) (Entered: 12/04/2013) |
| 2013-12-09 | 42 | REPLY MEMORANDUM OF LAW in Support re: 20 MOTION for Summary Judgment.. Document filed by United States Department of Homeland Security. (Tinio, Rebecca) (Entered: 12/09/2013) |
| 2013-12-09 | 43 | REPLY AFFIRMATION of Catrina Pavlic-Keenan in Support re: 20 MOTION for Summary Judgment.. Document filed by United States Department of Homeland Security. (Tinio, Rebecca) (Entered: 12/09/2013) |
| 2013-12-09 | 44 | REPLY AFFIRMATION of Rebecca S. Tinio in Support re: 20 MOTION for Summary Judgment.. Document filed by United States Department of Homeland Security. (Attachments: # 1 Exhibit A Pt. 1, # 2 Exhibit A Pt. 2, # 3 Exhibit A Pt. 3)(Tinio, Rebecca) (Entered: 12/09/2013) |
| 2013-12-09 | 45 | MEMORANDUM OF LAW in Opposition re: 33 MOTION to Compel Defendant, Department of Homeland Security to Produce Documents, or, in the alternative, for an In Camera Review, or, in the alternative, for Attorneys' Fees, Costs, and Expenses .. Document filed by United States Department of Homeland Security. (Tinio, Rebecca) (Entered: 12/09/2013) |
| 2013-12-10 | 46 | LETTER MOTION for Extension of Time to File Response/Reply as to 33 MOTION to Compel Defendant, Department of Homeland Security to Produce Documents, or, in the alternative, for an In Camera Review, or, in the alternative, for Attorneys' Fees, Costs, and Expenses . addressed to Judge Analisa Torres from Joel M. Ferdinand dated December 10, 2013. Document filed by Adam Conti.(Ferdinand, Joel) (Entered: 12/10/2013) |
| 2013-12-10 | 47 | ORDER. Plaintiff's request to file a brief reply is GRANTED. Plaintiff's reply is due by December 24, 2013. (HEREBY ORDERED by Judge Analisa Torres)(Text Only Order) (Torres, Analisa) (Entered: 12/10/2013) |
| 2013-12-24 | 48 | REPLY MEMORANDUM OF LAW in Support re: 33 MOTION to Compel Defendant, Department of Homeland Security to Produce Documents, or, in the alternative, for an In Camera Review, or, in the alternative, for Attorneys' Fees, Costs, and Expenses .. Document filed by Adam Conti. (Ferdinand, Joel) (Entered: 12/24/2013) |
| 2013-12-24 | 49 | REPLY AFFIRMATION of Counsel in Support re: 33 MOTION to Compel Defendant, Department of Homeland Security to Produce Documents, or, in the alternative, for an In Camera Review, or, in the alternative, for Attorneys' Fees, Costs, and Expenses .. Document filed by Adam Conti. (Ferdinand, Joel) (Entered: 12/24/2013) |
| 2014-01-28 | 50 | LETTER addressed to Judge Analisa Torres from Joel M. Ferdinand, Esq. dated January 28, 2014 re: Steven Kucan Sentencing. Document filed by Adam Conti.(Ferdinand, Joel) (Entered: 01/28/2014) |
| 2014-02-27 | 51 | LETTER addressed to Judge Analisa Torres from Rebecca S. Tinio dated 2/27/2014 Document filed by United States Department of Homeland Security.(Tinio, Rebecca) (Entered: 02/27/2014) |
| 2014-03-24 | 52 | MEMORANDUM AND ORDER. For the reasons stated in this Memorandum and Order, DHS' motion for summary judgment is GRANTED in part and DENIED in part. Plaintiff's cross motion is DENIED without prejudice to renewal. The Clerk of Court is directed to terminate the motions at ECF Nos. 20 and 33. Denying 33 Motion to Compel; Granting in part and denying in part 20 Motion for Summary Judgment. (Signed by Judge Analisa Torres on 3/24/2014) (rjm) (Entered: 03/24/2014) |
| 2014-07-17 | 53 | ORDER. Plaintiff's request for a pre-motion conference is DENIED without prejudice to renewal. By July 22, 2014, Plaintiff shall advise the Court as to whether Defendant has delivered the supplemental release of documents. (Signed by Judge Analisa Torres on 7/17/2014) (rjm) (Entered: 07/17/2014) |
| 2014-07-29 | 54 | LETTER addressed to Judge Analisa Torres from Rebecca S. Tinio dated July 29, 2014 re: Plaintiff's July 22, 2014 Letter. Document filed by United States Department of Homeland Security.(Tinio, Rebecca) (Entered: 07/29/2014) |
| 2014-07-29 | 55 | MEMO ENDORSEMENT on re: 54 Letter filed by United States Department of Homeland Security. ENDORSEMENT: DHS' request for permission to file a joint letter in thirty days updating the Court as to whether any issue remains and, if necessary, proposing a briefing schedule for a supplemental summary judgment motion, is GRANTED. (Signed by Judge Analisa Torres on 7/29/2014) (rjm) (Entered: 07/30/2014) |
| 2014-08-27 | 56 | LETTER addressed to Judge Analisa Torres from Rebecca S. Tinio dated August 27, 2014 re: Pursuant to the Court's July 29, 2014 Order. Document filed by United States Department of Homeland Security.(Tinio, Rebecca) (Entered: 08/27/2014) |
| 2014-08-27 | 57 | MEMO ENDORSEMENT on re: 56 Letter filed by United States Department of Homeland Security. ENDORSEMENT: GRANTED. The parties shall file a joint letter updating the Court, and if necessary, proposing a schedule for briefing the disputed issues, by September 18, 2014. SO ORDERED. (Signed by Judge Analisa Torres on 8/27/2014) (ama) (Entered: 08/27/2014) |
| 2014-09-18 | 58 | LETTER addressed to Judge Analisa Torres from Rebecca S. Tinio dated September 18, 2014 re: Request for Additional Time to Provide a Status Report. Document filed by United States Department of Homeland Security.(Tinio, Rebecca) (Entered: 09/18/2014) |
| 2014-09-18 | 59 | MEMO ENDORSEMENT on re: 58 Letter filed by United States Department of Homeland Security. ENDORSEMENT: GRANTED. SO ORDERED. (Signed by Judge Analisa Torres on 9/18/2014) (ajs) (Entered: 09/19/2014) |
| 2014-09-22 | 60 | LETTER addressed to Judge Analisa Torres from Rebecca S. Tinio dated September 22, 2014 re: Request to Submit a Further Status Report to the Court. Document filed by United States Department of Homeland Security.(Tinio, Rebecca) (Entered: 09/22/2014) |
| 2014-09-22 | 61 | LETTER addressed to Judge Analisa Torres from Joel M. Ferdinand dated September 22, 2014 re: Response to DHS' letter of September 22, 2014 and request for firm deadline for production. Document filed by Adam Conti.(Ferdinand, Joel) (Entered: 09/22/2014) |
| 2014-09-22 | 62 | MEMO ENDORSEMENT on re: 60 Letter filed by United States Department of Homeland Security. ENDORSEMENT: The government's request is GRANTED. The government shall make its additional document release and file a status letter with the Court by October 22, 2014. SO ORDERED. (Signed by Judge Analisa Torres on 9/22/2014) (ajs) (Entered: 09/22/2014) |
| 2014-10-22 | 63 | LETTER addressed to Judge Analisa Torres from Rebecca S. Tinio dated October 22, 2014 re: Status Letter. Document filed by United States Department of Homeland Security.(Tinio, Rebecca) (Entered: 10/22/2014) |
| 2014-10-22 | 64 | MEMO ENDORSEMENT on re: 63 Letter filed by United States Department of Homeland Security. ENDORSEMENT: The Government's request is GRANTED. The parties shall submit a joint status letter by November 21, 2014. SO ORDERED. (Signed by Judge Analisa Torres on 10/22/2014) (mro) (Entered: 10/23/2014) |
| 2014-11-20 | 65 | LETTER addressed to Judge Analisa Torres from Rebecca S. Tinio dated November 20, 2014 re: Joint Status Report. Document filed by United States Department of Homeland Security.(Tinio, Rebecca) (Entered: 11/20/2014) |
| 2014-11-20 | 66 | ORDER: The Court having been advised that all claims asserted herein have been settled, it is ORDERED that the above-entitled action be and is hereby dismissed and discontinued without costs and without prejudice to the right to reopen the action within thirty (30) days if the settlement is not consummated. Any pending motions are moot. All conferences are vacated. The Clerk of Court is directed to close the case. SO ORDERED. (Signed by Judge Analisa Torres on 11/20/2014) (ajs) (Entered: 11/20/2014) |
 Hide Docket Events |
|
