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Case TitlePROTECT DEMOCRACY PROJECT, INC. v. DEPARTMENT OF STATE
DistrictDistrict of Columbia
CityWashington, DC
Case Number1:2018cv00592
Date Filed2018-03-16
Date Closed2022-10-25
JudgeJudge Timothy J. Kelly
PlaintiffPROTECT DEMOCRACY PROJECT, INC.
Case DescriptionProtect Democracy Project submitted a FOIA request to the Department of State for records concerning communications from the White House that reference Sahar Nowrouzzadeh and other State Department employees subject to reassignment or termination. Protect Democracy Project also requested a fee waiver. The agency acknowledged receipt of the request, but after hearing nothing further from the agency, Protect Democracy Project filed suit.
Complaint issues: Failure to respond within statutory time limit, Adequacy - Search, Litigation - Vaughn index, Litigation - Attorney's fees

DefendantDEPARTMENT OF STATE
2201 C ST., NW
Washington, DC 20301
DefendantDEPARTMENT OF STATE
DefendantU.S. DEPARTMENT OF STATE
Documents
Docket
Complaint
Complaint attachment 1
Complaint attachment 2
Complaint attachment 3
Complaint attachment 4
Complaint attachment 5
Complaint attachment 6
User-contributed Documents
 
Docket Events (Hide)
Date FiledDoc #Docket Text

2018-03-161COMPLAINT against DEPARTMENT OF STATE ( Filing fee $ 400 receipt number 0090-5377623) filed by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Summons to Department of State, # 4 Summons to Attorney General, # 5 Summons to U.S. Attorney for D.C., # 6 Civil Cover Sheet)(Berwick, Benjamin) (Entered: 03/16/2018)
2018-03-16Case Assigned to Judge Timothy J. Kelly. (zsth) (Entered: 03/19/2018)
2018-03-192LCvR 7.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by PROTECT DEMOCRACY PROJECT, INC. (Berwick, Benjamin) (Entered: 03/19/2018)
2018-03-193SUMMONS (3) Issued Electronically as to DEPARTMENT OF STATE, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zsth) (Entered: 03/19/2018)
2018-04-094RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 4/5/2018. Answer due for ALL FEDERAL DEFENDANTS by 5/5/2018. (Berwick, Benjamin) (Entered: 04/09/2018)
2018-04-095RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 04/03/2018. (Berwick, Benjamin) (Entered: 04/09/2018)
2018-04-096RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. DEPARTMENT OF STATE served on 4/3/2018 (Berwick, Benjamin) (Entered: 04/09/2018)
2018-04-247NOTICE of Appearance by Claire M. Whitaker on behalf of U.S. DEPARTMENT OF STATE (Whitaker, Claire) (Entered: 04/24/2018)
2018-05-048Unopposed MOTION for Extension of Time to File Answer by U.S. DEPARTMENT OF STATE (Attachments: # 1 Text of Proposed Order)(Whitaker, Claire) (Entered: 05/04/2018)
2018-05-07MINUTE ORDER granting Defendant's 8 Consent Motion for Extension of Time to Answer. It is hereby ORDERED that Defendant shall file its response to Plaintiff's complaint by June 6, 2018. Signed by Judge Timothy J. Kelly on 5/7/2018. (lctjk3) (Entered: 05/07/2018)
2018-06-069NOTICE of Appearance by Johnny Hillary Walker, III on behalf of All Defendants (Walker, Johnny) (Entered: 06/06/2018)
2018-06-0610ANSWER to Complaint by U.S. DEPARTMENT OF STATE.(Walker, Johnny) (Entered: 06/06/2018)
2018-06-06MINUTE ORDER: Before the Court in this FOIA case are a complaint and an answer. It is hereby ORDERED that the parties shall meet, confer, and file a joint proposed schedule for briefing or disclosure by June 29, 2018. Signed by Judge Timothy J. Kelly on 6/6/2018. (lctjk3) (Entered: 06/06/2018)
2018-06-2911Joint STATUS REPORT by U.S. DEPARTMENT OF STATE. (Walker, Johnny) (Entered: 06/29/2018)
2018-07-02MINUTE ORDER: Upon review of the 11 Joint Status Report filed by the parties, it is hereby ORDERED that the parties shall file another joint status report by July 31, 2018. Signed by Judge Timothy J. Kelly on 7/2/2018. (lctjk3) (Entered: 07/02/2018)
2018-07-03Set/Reset Deadlines: Joint Status Report due by 7/31/2018. (kh) (Entered: 07/03/2018)
2018-07-3112Joint STATUS REPORT by U.S. DEPARTMENT OF STATE. (Walker, Johnny) (Entered: 07/31/2018)
2018-08-01MINUTE ORDER: Upon review of the 12 Joint Status Report filed by the parties, it is hereby ORDERED that the parties shall file another joint status report by September 13, 2018. Signed by Judge Timothy J. Kelly on 8/1/2018. (lctjk3) (Entered: 08/01/2018)
2018-09-1313Joint STATUS REPORT by U.S. DEPARTMENT OF STATE. (Walker, Johnny) (Entered: 09/13/2018)
2018-09-17MINUTE ORDER: Upon review of the 13 Joint Status Report filed by the parties, it is hereby ORDERED that the parties shall file another joint status report by October 12, 2018. Signed by Judge Timothy J. Kelly on 9/17/2018. (lctjk3) (Entered: 09/17/2018)
2018-10-1214Joint STATUS REPORT by U.S. DEPARTMENT OF STATE. (Walker, Johnny) (Entered: 10/12/2018)
2018-10-12MINUTE ORDER: In light of the parties' 14 Joint Status Report, it is hereby ORDERED that the parties shall file a further Joint Status Report by November 13, 2018. Signed by Judge Timothy J. Kelly on 10/12/2018. (lctjk1) (Entered: 10/12/2018)
2018-11-1315Joint STATUS REPORT by U.S. DEPARTMENT OF STATE. (Walker, Johnny) (Entered: 11/13/2018)
2018-11-18MINUTE ORDER: In light of the parties' 15 Joint Status Report, it is hereby ORDERED that the parties shall file a further Joint Status Report by February 11, 2019. Signed by Judge Timothy J. Kelly on 11/18/2018. (lctjk3) (Entered: 11/18/2018)
2019-01-2816NOTICE of Appearance by Cameron Oatman Kistler on behalf of PROTECT DEMOCRACY PROJECT, INC. (Kistler, Cameron) (Entered: 01/28/2019)
2019-02-0817Joint STATUS REPORT by U.S. DEPARTMENT OF STATE. (Walker, Johnny) (Entered: 02/08/2019)
2019-02-08MINUTE ORDER: In light of the parties' 17 Joint Status Report, it is hereby ORDERED that the parties shall file a further joint status report by May 13, 2019. Signed by Judge Timothy J. Kelly on 2/8/2019. (lctjk3) (Entered: 02/08/2019)
2019-05-1118Joint STATUS REPORT by U.S. DEPARTMENT OF STATE. (Walker, Johnny) (Entered: 05/11/2019)
2019-05-14MINUTE ORDER: In light of the parties' 18 Joint Status Report, it is hereby ORDERED that the parties shall file a further joint status report by August 5, 2019. Signed by Judge Timothy J. Kelly on 5/14/2019. (lctjk3) (Entered: 05/14/2019)
2019-08-0219Joint STATUS REPORT by U.S. DEPARTMENT OF STATE. (Walker, Johnny) (Entered: 08/02/2019)
2019-08-05MINUTE ORDER: In light of the parties' 19 Joint Status Report, it is hereby ORDERED that the parties shall file a further joint status report by September 5, 2019. Signed by Judge Timothy J. Kelly on 8/5/2019. (lctjk3) (Entered: 08/05/2019)
2019-09-0520Joint STATUS REPORT by U.S. DEPARTMENT OF STATE. (Walker, Johnny) (Entered: 09/05/2019)
2019-09-05MINUTE ORDER: Upon consideration of the parties' 20 Joint Status Report, it is hereby ORDERED that the parties shall file a further joint status report by December 20, 2019. Signed by Judge Timothy J. Kelly on 9/5/2019. (lctjk3) (Entered: 09/05/2019)
2019-12-2021Joint STATUS REPORT by U.S. DEPARTMENT OF STATE. (Walker, Johnny) (Entered: 12/20/2019)
2019-12-23MINUTE ORDER: Upon consideration of the parties' 21 Joint Status Report, it is hereby ORDERED that the parties shall file a further joint status report by January 17, 2020. Signed by Judge Timothy J. Kelly on 12/23/2019. (lctjk3) (Entered: 12/23/2019)
2020-01-1722Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Berwick, Benjamin) (Entered: 01/17/2020)
2020-01-22MINUTE ORDER: Upon consideration of the parties' 22 Joint Status Report, it is hereby ORDERED that the parties shall file a further joint status report by January 31, 2020. Signed by Judge Timothy J. Kelly on 1/22/2020. (lctjk3) (Entered: 01/22/2020)
2020-01-3023NOTICE of Appearance by Katherine Marie Anthony on behalf of PROTECT DEMOCRACY PROJECT, INC. (Anthony, Katherine) (Entered: 01/30/2020)
2020-01-3124Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Anthony, Katherine) (Entered: 01/31/2020)
2020-02-03MINUTE ORDER: Upon consideration of the parties' 24 Joint Status Report, it is hereby ORDERED that the parties shall file a further joint status report by February 14, 2020. Signed by Judge Timothy J. Kelly on 2/3/2020. (lctjk3) (Entered: 02/03/2020)
2020-02-1425Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Anthony, Katherine) (Entered: 02/14/2020)
2020-02-18MINUTE ORDER: Upon consideration of the parties' 25 Joint Status Report, it is hereby ORDERED that the parties shall file a further joint status report by February 28, 2020. Should the parties not resolve their dispute in its entirety by then, they shall include a proposed briefing schedule in the joint status report. Signed by Judge Timothy J. Kelly on 2/18/2020. (lctjk3) (Entered: 02/18/2020)
2020-02-2826Joint STATUS REPORT by U.S. DEPARTMENT OF STATE. (Walker, Johnny) (Entered: 02/28/2020)
2020-03-02MINUTE ORDER: Upon consideration of the parties' 26 Joint Status Report, it is hereby ORDERED that Defendant shall file its motion for summary judgment by April 24, 2020; Plaintiff shall file its opposition to Defendant's motion for summary judgment and its cross-motion for summary judgment by May 22, 2020; Defendant shall file its opposition to Plaintiff's cross-motion for summary judgment and reply in support of its motion for summary judgment by June 12, 2020; and Plaintiff shall file its reply in support of its cross-motion for summary judgment by June 26, 2020. (lctjk3) (Entered: 03/02/2020)
2020-04-2427Consent MOTION to Modify the Briefing Schedule by U.S. DEPARTMENT OF STATE (Attachments: # 1 Text of Proposed Order)(Walker, Johnny) (Entered: 04/24/2020)
2020-04-24MINUTE ORDER: Upon consideration of Defendant's 27 Consent Motion for Extension of Time, it is hereby ORDERED that Defendant shall file its motion for summary judgment by May 1, 2020; Plaintiff shall file its opposition to Defendant's motion for summary judgment and its cross-motion for summary judgment by May 29, 2020; Defendant shall file its opposition to Plaintiff's cross-motion for summary judgment and reply in support of its motion for summary judgment by June 19, 2020; and Plaintiff shall file its reply in support of its cross-motion for summary judgment by July 3, 2020. Signed by Judge Timothy J. Kelly on 4/24/2020. (lctjk3) (Entered: 04/24/2020)
2020-04-3028NOTICE of Appearance by Mehreen A Rasheed on behalf of PROTECT DEMOCRACY PROJECT, INC. (Rasheed, Mehreen) (Entered: 04/30/2020)
2020-05-0129MOTION for Summary Judgment by U.S. DEPARTMENT OF STATE (Attachments: # 1 Memorandum in Support, # 2 Statement of Facts, # 3 Declaration of Eric Stein (with exhibits), # 4 Text of Proposed Order)(Walker, Johnny) (Entered: 05/01/2020)
2020-05-2930Cross MOTION for Summary Judgment by PROTECT DEMOCRACY PROJECT, INC. (Attachments: # 1 Memorandum in Support, # 2 Statement of Facts, # 3 Declaration of Katherine M. Anthony, # 4 Exhibit A, # 5 Exhibit B, # 6 Text of Proposed Order)(Anthony, Katherine) (Entered: 05/29/2020)
2020-05-2931Memorandum in opposition to re 29 MOTION for Summary Judgment filed by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: # 1 Statement of Facts, # 2 Declaration of Katherine M. Anthony, # 3 Exhibit A, # 4 Exhibit B)(Anthony, Katherine) (Entered: 05/29/2020)
2020-06-1932Unopposed MOTION to Modify the Briefing Schedule by U.S. DEPARTMENT OF STATE (Attachments: # 1 Text of Proposed Order)(Walker, Johnny) (Entered: 06/19/2020)
2020-06-19MINUTE ORDER: Upon consideration of Defendant's 32 Unopposed Motion to Modify the Briefing Schedule, it is hereby ORDERED that Defendant shall file its opposition to Plaintiff's cross-motion for summary judgment and reply in support of its motion for summary judgment by July 10, 2020; and Plaintiff shall file its reply in support of its cross-motion for summary judgment by July 31, 2020. Signed by Judge Timothy J. Kelly on 6/19/2020. (lctjk3) (Entered: 06/19/2020)
2020-07-0933Unopposed MOTION for Extension of Time to File Response/Reply as to 29 MOTION for Summary Judgment , 30 Cross MOTION for Summary Judgment by U.S. DEPARTMENT OF STATE (Attachments: # 1 Text of Proposed Order)(Walker, Johnny) (Entered: 07/09/2020)
2020-07-09MINUTE ORDER: Upon consideration of Defendant's 33 Unopposed Motion for Extension of Time, it is hereby ORDERED that Defendant shall file its opposition to Plaintiff's cross-motion for summary judgment and reply in support of its motion for summary judgment by July 13, 2020. Signed by Judge Timothy J. Kelly on 7/9/2020. (lctjk3) (Entered: 07/09/2020)
2020-07-1334Consent MOTION for Extension of Time to File Response/Reply as to 29 MOTION for Summary Judgment , 30 Cross MOTION for Summary Judgment by U.S. DEPARTMENT OF STATE (Attachments: # 1 Text of Proposed Order)(Walker, Johnny) (Entered: 07/13/2020)
2020-07-14MINUTE ORDER granting, nunc pro tunc and for good cause shown, Defendant's 34 Consent Motion for Extension of Time. It is hereby ORDERED that Defendant shall file its opposition to Plaintiff's cross-motion for summary judgment and reply in support of its motion for summary judgment by July 17, 2020. Signed by Judge Timothy J. Kelly on 7/14/2020. (lctjk3) (Entered: 07/14/2020)
2020-07-1435Consent MOTION to Modify the July 14, 2020, minute order by U.S. DEPARTMENT OF STATE (Attachments: # 1 Text of Proposed Order)(Walker, Johnny) (Entered: 07/14/2020)
2020-07-14MINUTE ORDER granting Defendant's 35 Consent Motion to Modify. It is hereby ORDERED that Plaintiff shall file its reply in support of its cross-motion for summary judgment by August 14, 2020. Signed by Judge Timothy J. Kelly on 7/14/2020. (lctjk3) (Entered: 07/14/2020)
2020-07-1736REPLY to opposition to motion re 29 MOTION for Summary Judgment , 30 Cross MOTION for Summary Judgment filed by U.S. DEPARTMENT OF STATE. (Attachments: # 1 Response to Plaintiff's Statement of Facts, # 2 2 Decl. of Eric Stein (with 2d Vaughn index))(Walker, Johnny) (Entered: 07/17/2020)
2020-07-1737Memorandum in opposition to 30 Cross MOTION for Summary Judgment filed by U.S. DEPARTMENT OF STATE. (See Docket Entry 36 to view document) (ztth) (Entered: 07/20/2020)
2020-07-20NOTICE OF ERROR re 36 Reply to opposition to Motion; emailed to johnny.walker@usdoj.gov, cc'd 11 associated attorneys -- The PDF file you docketed contained errors: 1. Two-part docket entry, 2. DO NOT REFILE. In future, please docket all parts of pleading. (ztth, ) (Entered: 07/20/2020)
2020-08-1438REPLY to opposition to motion re 30 Cross MOTION for Summary Judgment filed by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: # 1 Declaration of Katherine M. Anthony)(Anthony, Katherine) (Entered: 08/14/2020)
2020-09-2339Unopposed MOTION for Leave to File Surreply by U.S. DEPARTMENT OF STATE (Attachments: # 1 Proposed Surreply)(Walker, Johnny) (Entered: 09/23/2020)
2020-09-25MINUTE ORDER granting Defendant's 39 Unopposed Motion for Leave to File a Surreply. The Clerks Office shall enter Defendant's surreply, ECF No. 39-1, on the docket. Signed by Judge Timothy J. Kelly on 9/25/2020. (lctjk3) (Entered: 09/25/2020)
2020-09-2540SURREPLY to re 30 Cross MOTION for Summary Judgment filed by U.S. DEPARTMENT OF STATE. (zrdj) (Entered: 09/25/2020)
2020-09-2542ENTERED IN ERROR. . . . .SURREPLY to re 30 Cross MOTION for Summary Judgment filed by U.S. DEPARTMENT OF STATE. (ztd) Modified on 9/28/2020 (ztd). (Entered: 09/28/2020)
2020-09-25NOTICE OF CORRECTED DOCKET ENTRY: re 42 Surreply was entered in error. Duplicate of docket entry no. 40 (ztd) (Entered: 09/28/2020)
2020-09-2641ERRATA by U.S. DEPARTMENT OF STATE 40 Surreply filed by U.S. DEPARTMENT OF STATE. (Attachments: # 1 3d Stein Decl. (with Supp. Vaughn Index))(Walker, Johnny) (Entered: 09/26/2020)
2020-10-0643Unopposed MOTION for Leave to File Surreply by PROTECT DEMOCRACY PROJECT, INC. (Attachments: # 1 Proposed Surreply)(Anthony, Katherine) (Entered: 10/06/2020)
2020-10-08MINUTE ORDER granting Plaintiff's 43 Unopposed Motion for Leave to File a Surreply. The Clerks Office shall enter Plaintiff's surreply, ECF No. 43-1, on the docket. The Court does not anticipate permitting further briefing on the parties' motions for summary judgment. Signed by Judge Timothy J. Kelly on 10/8/2020. (lctjk3) (Entered: 10/08/2020)
2020-10-0844SURREPLY to re 29 MOTION for Summary Judgment , 30 Cross MOTION for Summary Judgment filed by PROTECT DEMOCRACY PROJECT, INC.. (ztd) (Entered: 10/09/2020)
2021-11-1045NOTICE OF SUBSTITUTION OF COUNSEL by Douglas C. Dreier on behalf of U.S. DEPARTMENT OF STATE Substituting for attorney Johnny H. Walker, III (Dreier, Douglas) (Entered: 11/10/2021)
2022-03-28MINUTE ORDER denying without prejudice Defendant's 29 Motion for Summary Judgment and Plaintiff's 30 Cross-Motion for Summary Judgment. In this FOIA case, the parties have cross-moved for summary judgment as to the propriety of Defendant's withholdings under FOIA Exemption 5. See 5 U.S.C. § 552(b)(5). Exemption 5 protects inter-agency or intra-agency memorandums or letters that would not be available by law to a party other than an agency in litigation with the agency. One of the central disagreements between the parties involves Defendant's invocation of the deliberative process privilege to justify its withholding of the records in dispute, in full or in part. Defendant has the burden to show that this privilege, and thus Exemption 5 applies, and Defendant submitted a declaration and Vaughn Index in support of its motion. See 5 U.S.C. § 552(a)(4)(B); ECF No. 29-3. After briefing concluded, the D.C. Circuit issued two opinions that significantly clarify what an agency invoking the deliberative process privilege must show to meet its burden at summary judgment. In the first case, the Circuit explained that the "agency invoking the deliberative process privilege must show (1) what deliberative process is involved, and (2) the role played by the documents in issue in the course of that process." Jud. Watch, Inc. v. U.S. Dep't of Just. , 20 F.4th 49, 55 (D.C. Cir. 2021) (cleaned up). In addition, it "should also explain (3) the nature of the decisionmaking authority vested in the officer or person issuing the disputed document, and (4) the relative positions in the agency's chain of command occupied by the document's author and recipient." Id. (cleaned up). In the second case, the Circuit held that, with respect to an agency's explanation of foreseeable harm, "what is needed is a focused and concrete demonstration of why disclosure of the particular type of material at issue will, in the specific context of the agency action at issue, actually impede those same agency deliberations going forward." Reps. Comm. for Freedom of the Press v. FBI , 3 F.4th 350, 370 (D.C. Cir. 2021). Moreover, it pronounced that a "boilerplate, unparticularized, and hypothesized assertion of harm" was "insufficient." Id. The parties' briefing reflects disputes over precisely the issues in these cases: the required level of specificity Defendant must provide about the deliberative process affected and the foreseeable harm in disclosure. Further, the standard reflected in these cases may well undercut Defendant's position here, at least as the record now stands. In fact, Defendant cites the district court opinion reversed by the Circuit when arguing that the language in its declaration about the chilling effect of disclosure is sufficient for summary judgment. See ECF No. 36 at 13. Thus, upon the Court's review of the parties' briefing, Defendant's declaration and Vaughn index, and these recently-decided D.C. Circuit cases, it is hereby ORDERED that the parties' 29 30 motions for summary judgment are DENIED WITHOUT PREJUDICE. It is further ORDERED that by April 28, 2022, the parties shall meet and confer and file a joint status report regarding how they wish to proceed, including, if appropriate, a proposed schedule for renewed briefing or disclosure. Signed by Judge Timothy J. Kelly on 3/28/2022. (lctjk3) (Entered: 03/28/2022)
2022-04-2646Joint STATUS REPORT by U.S. DEPARTMENT OF STATE. (Attachments: # 1 Text of Proposed Order)(Dreier, Douglas) (Entered: 04/26/2022)
2022-04-29MINUTE ORDER: In light of the parties' 46 Joint Status Report, it is hereby ORDERED that Defendant shall file its motion for summary judgment by June 30, 2022; Plaintiff shall file its combined opposition and cross-motion for summary judgment by August 1, 2022; Defendant shall file its opposition and any reply by August 31, 2022; and Plaintiff shall file any reply by September 21, 2022. Signed by Judge Timothy J. Kelly on 4/29/2022. (lctjk3) (Entered: 04/29/2022)
2022-04-29Set/Reset Deadlines: Plaintiff's Cross Motion due by 8/1/2022. Response to Cross Motion due by 8/31/2022. Reply to Cross Motion due by 9/21/2022. (zkh) (Entered: 04/29/2022)
2022-06-3047MOTION for Summary Judgment by U.S. DEPARTMENT OF STATE. (Attachments: # 1 Memorandum in Support, # 2 Statement of Facts, # 3 Declaration of Susan C. Weetman, # 4 Exhibit 1 (Vaughn Index), # 5 Exhibit 2 (Initial Request Letter), # 6 Exhibit 3 (Acknowledgment Letter), # 7 Exhibit 4 (Release Letter), # 8 Exhibit 5 (Release Letter), # 9 Exhibit 6 (Release Letter), # 10 Exhibit 7 (Release Letter), # 11 Exhibit 8 (Release Letter), # 12 Exhibit 9 (Release Letter), # 13 Exhibit 10 (Release Letter), # 14 Exhibit 11 (Release Letter), # 15 Exhibit 12 (Release Letter), # 16 Exhibit 13 (Release Letter), # 17 Exhibit 14 (Release Letter), # 18 Exhibit 15 (Release Letter), # 19 Exhibit 16 (Release Letter), # 20 Exhibit 17 (Release Letter), # 21 Exhibit 18 (Release Letter), # 22 Text of Proposed Order)(Dreier, Douglas) (Entered: 06/30/2022)
2022-08-0148Cross MOTION for Summary Judgment by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: # 1 Memorandum in Support, # 2 Statement of Facts, # 3 Declaration of Mehreen Rasheed, # 4 Exhibit A (Released in Part Documents), # 5 Text of Proposed Order)(Rasheed, Mehreen) (Entered: 08/01/2022)
2022-08-0149Memorandum in opposition to re 47 Motion for Summary Judgment,,, filed by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: # 1 Statement of Facts, # 2 Declaration of Mehreen Rasheed, # 3 Exhibit A (Released in Part Documents))(Rasheed, Mehreen) (Entered: 08/01/2022)
2022-08-3150Memorandum in opposition to re 48 Motion for Summary Judgment, filed by U.S. DEPARTMENT OF STATE. (Attachments: # 1 Statement of Facts Response, # 2 Declaration of Susan C. Weetman (Second), # 3 Exhibit - Supplemental Vaughn Index, # 4 Text of Proposed Order)(Dreier, Douglas) (Entered: 08/31/2022)
2022-08-3151REPLY to opposition to motion re 47 MOTION for Summary Judgment - Duplicate of ECF No. 50 filed by U.S. DEPARTMENT OF STATE. (Dreier, Douglas) (Entered: 08/31/2022)
2022-09-1552Unopposed MOTION to Hold in Abeyance by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: # 1 Text of Proposed Order)(Rasheed, Mehreen) (Entered: 09/15/2022)
2022-09-16MINUTE ORDER granting Plaintiff's 52 Unopposed Motion to Hold Deadline in Abeyance. It is hereby ORDERED, for good cause shown, that Plaintiff's 52 Unopposed Motion is GRANTED. It is further ORDERED that Plaintiff's reply deadline of September 21, 2022, is STAYED until further order of the Court. It is further ORDERED that the parties shall submit a joint status report by October 17, 2022, updating the Court on the status of settlement negotiations, unless a stipulation of dismissal is filed before then. Signed by Judge Timothy J. Kelly on 9/16/2022. (lctjk3) (Entered: 09/16/2022)
2022-10-1753Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Rasheed, Mehreen) (Entered: 10/17/2022)
2022-10-18MINUTE ORDER: Upon consideration of the parties' 53 Joint Status Report, it is hereby ORDERED that the parties shall submit a further joint status report by November 17, 2022, unless a stipulation of dismissal is filed sooner. Signed by Judge Timothy J. Kelly on 10/18/2022. (lctjk3) (Entered: 10/18/2022)
2022-10-2454STIPULATION of Dismissal by U.S. DEPARTMENT OF STATE. (Dreier, Douglas) (Entered: 10/24/2022)
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