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Case TitleKHAN et al v. DEPARTMENT OF HOMELAND SECURITY (DHS) et al
DistrictDistrict of Columbia
CityWashington, DC
Case Number1:2022cv02480
Date Filed2022-08-19
Date ClosedOpen
JudgeJudge Timothy J. Kelly
PlaintiffFRAZ KHAN
PlaintiffMALIK AND ASSOCIATES PLLC
Case DescriptionFraz Khan submitted FOIA requests to the Department of Homeland Security and the Department of Justice for records concerning his arrest and detention. The agencies acknowledged receipt of the request but after hearing nothing further from the agencies, Khan filed suit.
Complaint issues: Failure to respond within statutory time limit, Adequacy - Search, Litigation - Vaughn index, Litigation - Attorney's fees

DefendantDEPARTMENT OF HOMELAND SECURITY (DHS)
DefendantDEPARTMENT OF HOMELAND SECURITY
DefendantCUSTOMS AND BORDER PROTECTION
DefendantCITIZENSHIP AND IMMIGRATION SERVICES
DefendantIMMIGRATION AND CUSTOMS ENFORCEMENT
DefendantFEDERAL BUREAU OF INVESTIGATION
DefendantALEJANDRO MAYORKAS Secretary of US DHS
DefendantALEJANDRO N. MAYORKAS Secretary of US DHS
DefendantALEJANDRO N. MAYORKAS Secretary of US DHS
TERMINATED: 10/24/2023
DefendantCHRIS MAGNUS Commissioner of the US CBP
DefendantCHRIS MAGNUS Commissioner of the US CBP
TERMINATED: 10/24/2023
DefendantUR JADDOU Director of USCIS
DefendantUR M. JADDOU Director of USCIS
DefendantUR M. JADDOU Director of USCIS
TERMINATED: 10/24/2023
DefendantUR MENDOZA JADDOU Director of USCIS
TERMINATED: 10/24/2023
DefendantTAE JOHNSON Acting Director US ICE
DefendantTAE JOHNSON Acting Director US ICE
TERMINATED: 10/24/2023
DefendantCHRISTOPHER WRAY Director of the FBI
DefendantCHRISTOPHER WRAY Director of the FBI
TERMINATED: 10/24/2023
Documents
Docket
Complaint
Complaint attachment 1
Complaint attachment 2
Opinion/Order [16]
Opinion/Order [23]
User-contributed Documents
 
Docket Events (Hide)
Date FiledDoc #Docket Text

2022-08-191COMPLAINT Original against All Defendants ( Filing fee $ 402 receipt number ADCDC-9454964) filed by MALIK AND ASSOCIATES PLLC, FRAZ KHAN. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit)(Malik, Adam) (Entered: 08/19/2022)
2022-08-192REQUEST FOR SUMMONS TO ISSUE filed by MALIK AND ASSOCIATES PLLC, FRAZ KHAN. (Attachments: # 1 Summons, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons, # 6 Summons, # 7 Summons, # 8 Summons, # 9 Summons)(Malik, Adam) (Entered: 08/19/2022)
2022-08-193SEALED DOCUMENT filed by FRAZ KHAN, MALIK AND ASSOCIATES PLLC re 1 Complaint (This document is SEALED and only available to authorized persons.)(Malik, Adam) (Entered: 08/19/2022)
2022-08-23Case Assigned to Judge Timothy J. Kelly. (zmrl) (Entered: 08/23/2022)
2022-08-234SUMMONS (10) Issued Electronically as to All Defendants. (Attachments: # 1 Notice and Consent)(zmrl) (Entered: 08/23/2022)
2022-08-23NOTICE OF ERROR re 2 Request for Summons to Issue; emailed to amalik@malikfirm.com, cc'd 0 associated attorneys -- The PDF file you docketed contained errors: 1. Missing summonses-government. When naming a government agent or agency as a defendant, you must supply a summons for each defendant & two additional summonses for the U.S. Attorney & U.S. Attorney General. Please submit using the event Request for Summons to Issue., 2. COMPLIANCE DEADLINE is by close of business today. This case will not proceed any further until all errors are satisfied. (zmrl, ) (Entered: 08/23/2022)
2022-08-235REQUEST FOR SUMMONS TO ISSUE re 2 Request for Summons to Issue filed by MALIK AND ASSOCIATES PLLC, FRAZ KHAN. Related document: 2 Request for Summons to Issue filed by MALIK AND ASSOCIATES PLLC, FRAZ KHAN. (Attachments: # 1 Summons)(Malik, Adam) (Entered: 08/23/2022)
2022-08-246SUMMONS (2) Issued Electronically as to U.S. Attorney and U.S. Attorney General. (ztth) (Entered: 08/24/2022)
2022-10-187Consent MOTION for Extension of Time to Answer or Otherwise Respond to Complaint by CITIZENSHIP AND IMMIGRATION SERVICES, CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY (DHS), FEDERAL BUREAU OF INVESTIGATION, IMMIGRATION AND CUSTOMS ENFORCEMENT, UR JADDOU, TAE JOHNSON, CHRIS MAGNUS, ALEJANDRO MAYORKAS, CHRISTOPHER WRAY. (Attachments: # 1 Proposed Order)(Simon, Jeremy) (Entered: 10/18/2022)
2022-10-19MINUTE ORDER granting Defendants' 7 Consent Motion for Extension of Time to Answer or Otherwise Respond to 1 Complaint. It is hereby ORDERED, for good cause shown, that Defendants' 7 Consent Motion for Extension of Time is GRANTED. It is further ORDERED that Defendants shall file a response to Plaintiff's complaint by November 18, 2022. Signed by Judge Timothy J. Kelly on 10/19/2022. (lctjk2) (Entered: 10/19/2022)
2022-11-178Consent MOTION for Extension of Time to Answer or Otherwise Respond to Complaint by CITIZENSHIP AND IMMIGRATION SERVICES, CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY (DHS), FEDERAL BUREAU OF INVESTIGATION, IMMIGRATION AND CUSTOMS ENFORCEMENT, UR JADDOU, TAE JOHNSON, CHRIS MAGNUS, ALEJANDRO MAYORKAS, CHRISTOPHER WRAY. (Attachments: # 1 Proposed Order)(Simon, Jeremy) (Entered: 11/17/2022)
2022-11-17MINUTE ORDER granting Defendants' 8 Consent Motion for Extension of Time to Answer or Otherwise Respond to 1 Complaint. It is hereby ORDERED, for good cause shown, that Defendants' 8 Consent Motion for Extension of Time is GRANTED. It is further ORDERED that Defendants shall file a response to Plaintiffs' complaint by December 1, 2022. Signed by Judge Timothy J. Kelly on 11/17/2022. (lctjk2) (Entered: 11/17/2022)
2022-11-179STANDING ORDER. See Order for details. Signed by Judge Timothy J. Kelly on 11/17/2022. (lctjk2) (Entered: 11/17/2022)
2022-12-0110MOTION to Dismiss in Part , MOTION to Strike 1 Complaint (Motion to Strike Remainder of Complaint) by CITIZENSHIP AND IMMIGRATION SERVICES, CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, FEDERAL BUREAU OF INVESTIGATION, IMMIGRATION AND CUSTOMS ENFORCEMENT, UR JADDOU, TAE JOHNSON, CHRIS MAGNUS, ALEJANDRO MAYORKAS, CHRISTOPHER WRAY. (Attachments: # 1 Proposed Order)(Simon, Jeremy) (Entered: 12/01/2022)
2022-12-1511Consent MOTION for Extension of Time to File Response/Reply as to 10 MOTION to Dismiss in Part MOTION to Strike 1 Complaint (Motion to Strike Remainder of Complaint) by FRAZ KHAN, MALIK AND ASSOCIATES PLLC. (Attachments: # 1 Proposed Order)(Malik, Adam) (Entered: 12/15/2022)
2022-12-16MINUTE ORDER granting Plaintiffs' 11 Consent Motion For Extension Of Time To File Response To 10 Motion To Dismiss. It is hereby ORDERED, for good cause shown, that Plaintiffs' 11 Motion is GRANTED. It is further ORDERED that Plaintiffs shall file their response to Defendants' 10 Motion To Dismiss In Part And To Strike Remainder Of Complaint by January 6, 2023. Signed by Judge Timothy J. Kelly on 12/16/2022. (lctjk2) (Entered: 12/16/2022)
2023-01-0612Memorandum in opposition to re 10 Motion to Dismiss,, Motion to Strike, Response to Motion to Dismiss filed by FRAZ KHAN. (Attachments: # 1 Text of Proposed Order Proposed Order, # 2 Exhibit Exhibits)(Malik, Adam) (Entered: 01/06/2023)
2023-01-1113Consent MOTION for Extension of Time to File Reply in Support of Motion to Dismiss in Part and to Strike by CITIZENSHIP AND IMMIGRATION SERVICES, CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, FEDERAL BUREAU OF INVESTIGATION, IMMIGRATION AND CUSTOMS ENFORCEMENT, UR JADDOU, TAE JOHNSON, CHRIS MAGNUS, ALEJANDRO MAYORKAS, CHRISTOPHER WRAY. (Attachments: # 1 Proposed Order)(Simon, Jeremy) (Entered: 01/11/2023)
2023-01-11MINUTE ORDER granting Defendants' 13 Consent Motion for Extension of Time to File Reply in Support of 10 Motion to Dismiss in Part and to Strike. It is hereby ORDERED, for good cause shown, that Defendants' 13 Consent Motion is GRANTED. It is further ORDERED that Defendants shall file their reply in support of the 10 Motion to Dismiss in Part and to Strike by January 30, 2023. Signed by Judge Timothy J. Kelly on 1/11/2023. (lctjk2) (Entered: 01/11/2023)
2023-01-2614Consent MOTION for Extension of Time to File Reply In Support of Motion to Dismiss in Part and to Strike by CITIZENSHIP AND IMMIGRATION SERVICES, CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, FEDERAL BUREAU OF INVESTIGATION, IMMIGRATION AND CUSTOMS ENFORCEMENT, UR JADDOU, TAE JOHNSON, CHRIS MAGNUS, ALEJANDRO MAYORKAS, CHRISTOPHER WRAY. (Attachments: # 1 Proposed Order)(Simon, Jeremy) (Entered: 01/26/2023)
2023-01-30MINUTE ORDER granting Defendants' 14 Consent Motion for Extension of Time to File Reply in Support of 10 Motion to Dismiss in Part and to Strike. It is hereby ORDERED, for good cause shown, that Defendants' 14 Consent Motion is GRANTED. It is further ORDERED that Defendants shall file their reply in support of the 10 Motion to Dismiss in Part and to Strike by February 3, 2023. Signed by Judge Timothy J. Kelly on 1/30/2023. (lctjk2) (Entered: 01/30/2023)
2023-02-0315REPLY to opposition to motion re 10 MOTION to Dismiss in Part MOTION to Strike 1 Complaint (Motion to Strike Remainder of Complaint) filed by CITIZENSHIP AND IMMIGRATION SERVICES, CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, FEDERAL BUREAU OF INVESTIGATION, IMMIGRATION AND CUSTOMS ENFORCEMENT, UR JADDOU, TAE JOHNSON, CHRIS MAGNUS, ALEJANDRO MAYORKAS, CHRISTOPHER WRAY. (Simon, Jeremy) (Entered: 02/03/2023)
2023-09-2516MEMORANDUM OPINION AND ORDER granting in part and denying in part Defendants' 10 Motion to Dismiss in Part and to Strike Remainder of Complaint. See Memorandum Opinion and Order for details. Signed by Judge Timothy J. Kelly on 9/25/2023. (lctjk2) (Entered: 09/25/2023)
2023-10-2417STRICKEN PURSUANT TO ORDER FILED 9/12/2024..... AMENDED COMPLAINT against CITIZENSHIP AND IMMIGRATION SERVICES, CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, FEDERAL BUREAU OF INVESTIGATION, IMMIGRATION AND CUSTOMS ENFORCEMENT filed by FRAZ KHAN. (Attachments: # 1 Exhibit Exhibits A-D, # 2 Exhibit Exhibits E-G)(Malik, Adam) Modified to strike on 9/12/2024 (zkh). (Entered: 10/24/2023)
2023-10-2418SEALED DOCUMENT filed by FRAZ KHAN re 17 Amended Complaint, (This document is SEALED and only available to authorized persons.)(Malik, Adam) (Entered: 10/24/2023)
2023-11-0619MOTION for Extension of Time to Answer or Otherwise Respond to Amended Complaint by CITIZENSHIP AND IMMIGRATION SERVICES, CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, FEDERAL BUREAU OF INVESTIGATION, IMMIGRATION AND CUSTOMS ENFORCEMENT. (Attachments: # 1 Proposed Order)(Simon, Jeremy) (Entered: 11/06/2023)
2023-11-08MINUTE ORDER treating as opposed and granting Defendants' 19 Motion for Extension of Time to Answer or Otherwise Respond. Upon consideration of Defendants' 19 Motion, it is hereby ORDERED, nunc pro tunc to November 7, 2023, and for good cause shown, that the motion is granted. It is further ORDERED that Defendants shall answer or otherwise respond to the amended complaint by November 28, 2023. Signed by Judge Timothy J. Kelly on 11/8/2023. (lctjk2) (Entered: 11/08/2023)
2023-11-2820MOTION to Dismiss or Alternatively , MOTION to Strike 17 Amended Complaint, and Supporting Memorandum by CITIZENSHIP AND IMMIGRATION SERVICES, CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, FEDERAL BUREAU OF INVESTIGATION, IMMIGRATION AND CUSTOMS ENFORCEMENT. (Attachments: # 1 Proposed Order)(Simon, Jeremy) (Entered: 11/28/2023)
2023-12-1221Memorandum in opposition to re 20 Motion to Dismiss,, Motion to Strike, filed by FRAZ KHAN. (Attachments: # 1 Proposed Order)(Malik, Adam) (Entered: 12/12/2023)
2023-12-1922REPLY to opposition to motion re 20 MOTION to Dismiss or Alternatively MOTION to Strike 17 Amended Complaint, and Supporting Memorandum filed by CITIZENSHIP AND IMMIGRATION SERVICES, CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, FEDERAL BUREAU OF INVESTIGATION, IMMIGRATION AND CUSTOMS ENFORCEMENT. (Simon, Jeremy) (Entered: 12/19/2023)
2024-09-1223MEMORANDUM OPINION AND ORDER granting Defendants' 20 Motion to Dismiss or to Strike, striking Plaintiffs' Amended Complaint, and ordering Plaintiffs to file a second amended complaint by October 11, 2024. See Memorandum Opinion and Order for details. Signed by Judge Timothy J. Kelly on 9/12/2024. (lctjk2) (Entered: 09/12/2024)
2024-09-12Set/Reset Deadlines: Second Amended Complaint due by 10/11/2024. (zkh) (Entered: 09/12/2024)
2024-10-1124AMENDED COMPLAINT SECOND against CITIZENSHIP AND IMMIGRATION SERVICES, CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, FEDERAL BUREAU OF INVESTIGATION, IMMIGRATION AND CUSTOMS ENFORCEMENT filed by MALIK AND ASSOCIATES PLLC, FRAZ KHAN. (Attachments: # 1 Exhibit)(Malik, Adam) (Entered: 10/11/2024)
2024-10-2225Consent MOTION for Extension of Time to Respond to Second Amended Complaint by CITIZENSHIP AND IMMIGRATION SERVICES, CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, FEDERAL BUREAU OF INVESTIGATION, IMMIGRATION AND CUSTOMS ENFORCEMENT. (Attachments: # 1 Proposed Order)(Simon, Jeremy) (Entered: 10/22/2024)
2024-10-23MINUTE ORDER granting Defendants' 25 Consent Motion for Extension of Time to Respond to Second Amended Complaint. It is hereby ORDERED, for good cause shown, that Defendants' 25 Consent Motion is GRANTED. Defendants shall respond to Plaintiffs' 24 Second Amended Verified Complaint for Declaratory and Injunctive Relief by November 8, 2024. Signed by Judge Timothy J. Kelly on 10/23/2024. (lctjk2) (Entered: 10/23/2024)
2024-11-0826ANSWER to 24 Amended Complaint, by DEPARTMENT OF HOMELAND SECURITY, CUSTOMS AND BORDER PROTECTION, CITIZENSHIP AND IMMIGRATION SERVICES, IMMIGRATION AND CUSTOMS ENFORCEMENT, FEDERAL BUREAU OF INVESTIGATION.(Simon, Jeremy) (Entered: 11/08/2024)
2024-11-11MINUTE ORDER: Before the Court in this FOIA case is a second amended complaint and an answer. It is hereby ORDERED that the parties shall meet, confer, and file, by November 25, 2024, a joint proposed schedule for briefing or disclosure. Signed by Judge Timothy J. Kelly on 11/11/2024. (lctjk2) (Entered: 11/11/2024)
2024-11-2527Joint STATUS REPORT by DEPARTMENT OF HOMELAND SECURITY, CUSTOMS AND BORDER PROTECTION, CITIZENSHIP AND IMMIGRATION SERVICES, IMMIGRATION AND CUSTOMS ENFORCEMENT, FEDERAL BUREAU OF INVESTIGATION. (Simon, Jeremy) (Entered: 11/25/2024)
2024-11-26MINUTE ORDER: Upon consideration of the parties' 27 Joint Status Report, it is hereby ORDERED that the following briefing schedule shall govern summary-judgment briefing in this case: Defendants shall file their motion for summary judgment by February 20, 2025; Plaintiffs shall file their opposition to Defendants' motion and any cross-motion for summary judgment by April 3, 2025; Defendants shall file their reply and any opposition to Plaintiffs' cross-motion by April 24, 2025; and Plaintiffs shall file any reply in support of their cross-motion by May 15, 2025. Additionally, to the extent the 27 Joint Status Report constitutes a motion by Plaintiffs for a Vaughn index, the Court concludes that such a motion is "untimely and premature" as "the court's resolution of any dispositive motions and affidavits which might be filed with regard to plaintiff[s'] claim against [Defendants] could moot a Vaughn Index motion." Stimac v. DOJ , 620 F. Supp. 212, 213 (D.D.C. 1985). Thus, it is further ORDERED that Plaintiffs' motion is DENIED WITHOUT PREJUDICE. Signed by Judge Timothy J. Kelly on 11/26/2024. (lctjk2) (Entered: 11/26/2024)
2025-02-1828Consent MOTION for Extension of Time to File Motion for Summary Judgment by DEPARTMENT OF HOMELAND SECURITY, CUSTOMS AND BORDER PROTECTION, CITIZENSHIP AND IMMIGRATION SERVICES, IMMIGRATION AND CUSTOMS ENFORCEMENT, FEDERAL BUREAU OF INVESTIGATION. (Attachments: # 1 Proposed Order)(Simon, Jeremy) (Entered: 02/18/2025)
2025-02-19MINUTE ORDER granting Defendants' 28 Consent Motion for Extension of Time to File Motion for Summary Judgment. Upon consideration of Defendants' 28 Consent Motion, and because Plaintiffs consent to the relief sought, it is hereby ORDERED that Defendants' 28 Consent Motion is GRANTED. It is further ORDERED that the briefing schedule set forth in the Court's Minute Order of November 26, 2024, shall be MODIFIED as follows: Defendants shall file their motion for summary judgment by March 6, 2025; Plaintiffs shall file their opposition to Defendants' motion and any cross-motion for summary judgment by April 17, 2025; Defendants shall file their reply and any opposition to Plaintiffs' cross-motion by May 8, 2025; and Plaintiffs shall file any reply in support of their cross-motion by May 29, 2025. Signed by Judge Timothy J. Kelly on 2/19/2025. (lctjk2) (Entered: 02/19/2025)
2025-03-0529Consent MOTION for Extension of Time to File Motion for Summary Judgment by DEPARTMENT OF HOMELAND SECURITY, CUSTOMS AND BORDER PROTECTION, CITIZENSHIP AND IMMIGRATION SERVICES, IMMIGRATION AND CUSTOMS ENFORCEMENT, FEDERAL BUREAU OF INVESTIGATION. (Attachments: # 1 Proposed Order)(Simon, Jeremy) (Entered: 03/05/2025)
2025-03-06MINUTE ORDER granting Defendants' 29 Consent Motion for Extension of Time to File Motion for Summary Judgment. Upon consideration of Defendants' 29 Consent Motion, and because Plaintiffs consent to the relief sought, it is hereby ORDERED that Defendants' 29 Consent Motion is GRANTED. It is further ORDERED that the briefing schedule set forth in the Court's Minute Order of February 19, 2025, shall be MODIFIED as follows: Defendants shall file their motion for summary judgment by March 18, 2025; Plaintiffs shall file their opposition to Defendants' motion and any cross-motion for summary judgment by May 29, 2025; Defendants shall file their reply and any opposition to Plaintiffs' cross-motion by June 20, 2025; and Plaintiffs shall file any reply in support of their cross-motion by July 20, 2025. Signed by Judge Timothy J. Kelly on 3/6/2025. (lctjk2) Modified to correct cross-motion reply date on 3/6/2025 (zkh). (Entered: 03/06/2025)
2025-03-1830MOTION for Summary Judgment and Supporting Memorandum by DEPARTMENT OF HOMELAND SECURITY, CUSTOMS AND BORDER PROTECTION, CITIZENSHIP AND IMMIGRATION SERVICES, IMMIGRATION AND CUSTOMS ENFORCEMENT, FEDERAL BUREAU OF INVESTIGATION. (Attachments: # 1 Local Rule 7(h) Statement, # 2 Declaration of Shari Suzuki, # 3 Declaration of Patrick Howard, # 4 Declaration of Christian Esteves, # 5 Declaration of James A. Baxley, # 6 Declaration of Michael G. Seidel, # 7 Declaration of Fernando Pineiro, # 8 Proposed Order)(Simon, Jeremy) (Entered: 03/18/2025)
2025-03-1831MOTION for Leave File Submit Declaration Under Seal and Ex Parte, In Camera in Support of Motion for Summary Judgment re 30 MOTION for Summary Judgment and Supporting Memorandum by CUSTOMS AND BORDER PROTECTION. (Attachments: # 1 Proposed Order)(Simon, Jeremy) Modified event on 3/19/2025 (znmw). (Entered: 03/18/2025)
2025-04-0132RESPONSE re 31 MOTION for Leave to File Ex Parte and IN Camera filed by FRAZ KHAN, MALIK AND ASSOCIATES PLLC. (Attachments: # 1 Text of Proposed Order)(Malik, Adam) (Entered: 04/01/2025)
2025-04-01RESOLVED.....NOTICE of Provisional/Government Not Certified Status re 32 RESPONSE re 31 MOTION for Leave to File Ex Parte and IN Camera filed by FRAZ KHAN, MALIK AND ASSOCIATES PLLC. (Attachments: # 1 Text of Proposed Order)(Malik, Adam). Your attorney renewal/government certification has not been received. As a result, your membership with the U.S. District & Bankruptcy Courts for the District of Columbia is not in good standing, and you are not permitted to file. Pursuant to Local Civil Rule 83.9, you must immediately correct your membership status by following the appropriate instructions on this page of our website: https://www.dcd.uscourts.gov/attorney-renewal. Please be advised that the presiding judge in this case has been notified that you are currently not in good standing to file in this court. Renewal Due by 4/8/2025. (zhcn) 4/2/2025 (zapb). (Entered: 04/02/2025)
2025-04-0833REPLY to opposition to motion re 31 Motion for Leave to File, filed by CUSTOMS AND BORDER PROTECTION. (Simon, Jeremy) (Entered: 04/08/2025)
2025-04-09MINUTE ORDER: Before the Court is Defendants' 31 Motion for Leave to Submit Declaration Under Seal and Ex Parte, In Camera . In ruling on such motions, however, courts often review both the proposed declaration and the public record. E.g., Brick v. DOJ , 358 F. Supp. 3d 37, 46 (D.D.C. 2019); Shapiro v. DOJ , 239 F. Supp. 3d 100, 111 (D.D.C. 2017). Thus, it is hereby ORDERED that Defendants shall, by May 8, 2025, submit, sealed and ex parte , its proposed declaration. Signed by Judge Timothy J. Kelly on 4/9/2025. (lctjk2) (Entered: 04/09/2025)
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