Case: 1:17-cv-02225-JDB As of: 01/24/2019 05:08 AM EST 1 of 4 STAYED,TYPE I−FOIA U.S. District Court District of Columbia (Washington, DC) CIVIL DOCKET FOR CASE #: 1:17−cv−02225−JDB PROTECT DEMOCRACY PROJECT, INC. v. U.S. Date Filed: 10/26/2017 DEPARTMENT OF JUSTICE et al Jury Demand: None Assigned to: Judge John D. Bates Nature of Suit: 895 Freedom of Cause: 05:552 Freedom of Information Act Information Act Jurisdiction: U.S. Government Defendant Plaintiff PROTECT DEMOCRACY represented by Anne Harden Tindall PROJECT, INC. PROTECT DEMOCRACY PROJECT 2020 Pennsylvania Avenue, NW #163 Washington, DC 20006 (202) 856−9191 Fax: (929) 777−8428 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED Justin G. Florence PROTECT DEMOCRACY PROJECT 2020 Pennsylvania Avenue, NW #163 Washington, DC 20006 (202) 599−0466 Fax: (929) 777−8428 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED Allison F. Murphy PROTECT DEMOCRACY PROJECT 2020 Pennsylvania Avenue, NW #163 Washington, DC 20006 (202) 417−2341 Email: [email protected] TERMINATED: 08/01/2018 V. Defendant U.S. DEPARTMENT OF JUSTICE represented by Daniel Patrick Schaefer U.S. ATTORNEY'S OFFICE FOR THE DISTRICT OF COLUMBIA 555 Fourth Street, NW Washington, DC 20530 (202) 252−2531 Fax: (202) 252−2599 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED Defendant U.S. DEPARTMENT OF DEFENSE represented by Daniel Patrick Schaefer (See above for address) LEAD ATTORNEY Case: 1:17-cv-02225-JDB As of: 01/24/2019 05:08 AM EST 2 of 4 ATTORNEY TO BE NOTICED Defendant U.S. DEPARTMENT OF STATE represented by Daniel Patrick Schaefer (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Date Filed # Docket Text 10/26/2017 1 COMPLAINT against U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE ( Filing fee $ 400 receipt number 0090−5177907) filed by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: # 1 Civil Cover Sheet, # 2 Summons AG Summons, # 3 Summons US Atty Summons, # 4 Summons DOJ Summons, # 5 Summons DOD Summons, # 6 Summons State Summons, # 7 Exhibit Exhibit A, # 8 Exhibit Exhibit B, # 9 Exhibit Exhibit C, # 10 Exhibit Exhibit D, # 11 Exhibit Exhibit E, # 12 Exhibit Exhibit F, # 13 Exhibit Exhibit G, # 14 Exhibit Exhibit H, # 15 Exhibit Exhibit I, # 16 Exhibit Exhibit J, # 17 Exhibit Exhibit K, # 18 Declaration Certificate LCvR 7−1)(Florence, Justin) (Entered: 10/26/2017) 10/27/2017 2 LCvR 7.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by PROTECT DEMOCRACY PROJECT, INC. (md) (Entered: 10/27/2017) 10/27/2017 Case Assigned to Judge John D. Bates. (md) (Entered: 10/27/2017) 10/27/2017 3 ENTERED IN ERROR.....SUMMONS (5) Issued Electronically as to U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice of Consent) (md) Modified on 11/3/2017 (zmd). (Entered: 10/27/2017) 11/03/2017 SUMMONS (5) Not Issued as to U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE, U.S. Attorney, U.S. Attorney General. (INCORRECT SUMMONS SUBMITTED AT THE TIME COMPLAINT WAS FILED. FOIA SUMMONS NEED TO BE FILED) (zmd) (Entered: 11/03/2017) 11/03/2017 4 REQUEST FOR SUMMONS TO ISSUE ON CORRECT FOIA SUMMONS FORMS re 1 Complaint,, filed by PROTECT DEMOCRACY PROJECT, INC.. Related document: 1 Complaint,, filed by PROTECT DEMOCRACY PROJECT, INC..(Florence, Justin) (Entered: 11/03/2017) 11/06/2017 5 SUMMONS (5) Re−Issued Electronically as to U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE, U.S. Attorney and U.S. Attorney General (znmw) (Entered: 11/06/2017) 11/17/2017 6 RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 11/14/2017. (Florence, Justin) (Main Document 6 replaced on 11/20/2017) (znmw). (Entered: 11/17/2017) 11/17/2017 7 RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 11/14/2017. Answer due for ALL FEDERAL DEFENDANTS by 12/14/2017. (Florence, Justin) (Main Document 7 replaced on 11/20/2017) (znmw). (Entered: 11/17/2017) 11/17/2017 8 RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. DEPARTMENT OF DEFENSE served on 11/13/2017; U.S. DEPARTMENT OF JUSTICE served on 11/14/2017; U.S. DEPARTMENT OF STATE served on 11/14/2017 (Florence, Justin) (Main Document 8 replaced on 11/20/2017) (znmw). (Entered: 11/17/2017) 12/13/2017 9 NOTICE of Appearance by Daniel Patrick Schaefer on behalf of U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE (Schaefer, Daniel) (Entered: 12/13/2017) Case: 1:17-cv-02225-JDB As of: 01/24/2019 05:08 AM EST 3 of 4 12/13/2017 10 Consent MOTION for Extension of Time to File Answer re 1 Complaint,, by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE (Attachments: # 1 Text of Proposed Order)(Schaefer, Daniel) (Entered: 12/13/2017) 12/13/2017 MINUTE ORDER: Upon consideration of 10 defendants' consent motion for an extension of time to answer or otherwise respond to plaintiff's complaint, and the entire record herein, it is hereby ORDERED that the motion is GRANTED; and it is further ORDERED that the defendants shall answer or otherwise respond to the complaint by not later than Thursday, January 11, 2018. Signed by Judge John D. Bates on 12/13/2017. (lcjdb1) (Entered: 12/13/2017) 12/18/2017 11 REQUEST FOR SUMMONS TO ISSUE WITH CORRECTED ADDRESS TO STATE DEPARTMENT re 1 Complaint,, filed by PROTECT DEMOCRACY PROJECT, INC.. Related document: 1 Complaint,, filed by PROTECT DEMOCRACY PROJECT, INC..(Florence, Justin) (Entered: 12/18/2017) 12/20/2017 12 SUMMONS (1) Reissued Electronically as to U.S. DEPARTMENT OF STATE (td) (Entered: 12/20/2017) 01/02/2018 13 RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. DEPARTMENT OF STATE served on 12/27/2017 (Florence, Justin) (Entered: 01/02/2018) 01/11/2018 14 ANSWER to 1 Complaint by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE.(Schaefer, Daniel) Modified to add link on 1/12/2018 (znmw). (Entered: 01/11/2018) 01/12/2018 15 SCHEDULING ORDER. See text of Order for details. Signed by Judge John D. Bates on 1/12/2018. (lcjdb1) (Entered: 01/12/2018) 01/17/2018 ENTERED IN ERROR....Set/Reset Deadlines: Proposed Briefing Schedule due by 2/12/2018. (tb) Modified on 1/17/2018 (tb). (Entered: 01/17/2018) 01/17/2018 NOTICE OF CORRECTED DOCKET ENTRY: A set/reset deadline was entered in error in this case on 01/17/18 and counsel is instructed to disregard that entry. (tb) (Entered: 01/17/2018) 02/12/2018 16 Joint STATUS REPORT and Joint Proposed Schedule for Further Proceedings by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE. (Attachments: # 1 Text of Proposed Order)(Schaefer, Daniel) (Entered: 02/12/2018) 02/13/2018 MINUTE ORDER: Upon consideration of 16 the parties' joint status report, and the entire record herein, it is hereby ORDERED that defendants shall issue their first interim responses to plaintiff's requests by not later than Tuesday, March 20, 2018; and it is further ORDERED that, if this matter has not been resolved by Tuesday, March 27, 2018, the parties shall file a further joint status report on that date. SO ORDERED. Signed by Judge John D. Bates on 2/13/2018. (lcjdb1) (Entered: 02/13/2018) 02/13/2018 Set/Reset Deadlines: If this matter has not been resolved by 3/27/2018 then the parties shall file Joint Status Report by 3/27/2018. (tb) (Entered: 02/13/2018) 03/27/2018 17 NOTICE of Appearance by Allison F. Murphy on behalf of PROTECT DEMOCRACY PROJECT, INC. (Murphy, Allison) (Entered: 03/27/2018) 03/27/2018 18 Joint STATUS REPORT by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE. (Attachments: # 1 Text of Proposed Order)(Schaefer, Daniel) (Entered: 03/27/2018) 04/24/2018 19 SCHEDULING ORDER. See text of order for details. Signed by Judge John D. Bates on 4/24/2018. (lcjdb1) (Entered: 04/24/2018) 04/25/2018 Set/Reset Deadlines: Joint Status Report and proposed production schedule due by 4/26/2018. Joint Status Report on the all defendants' processing and responses and proposed schedule due by 5/25/2018. (tb) (Entered: 04/25/2018) 04/26/2018 20 Joint STATUS REPORT by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE. (Schaefer, Daniel) Case: 1:17-cv-02225-JDB As of: 01/24/2019 05:08 AM EST 4 of 4 (Entered: 04/26/2018) 05/25/2018 21 Joint STATUS REPORT by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE. (Attachments: # 1 Text of Proposed Order)(Schaefer, Daniel) (Entered: 05/25/2018) 05/30/2018 MINUTE ORDER: Upon consideration of 21 the parties' joint status report, and the entire record herein, it is hereby ORDERED that the parties shall submit another joint status report by not later than Thursday, August 23, 2018. Signed by Judge John D. Bates on 5/30/2018. (lcjdb1) (Entered: 05/30/2018) 05/30/2018 Set/Reset Deadlines: Joint Status Report due by 8/23/2018. (tb) (Entered: 05/30/2018) 08/01/2018 22 NOTICE OF WITHDRAWAL OF APPEARANCE as to PROTECT DEMOCRACY PROJECT, INC.. Attorney Allison F. Murphy terminated. (Murphy, Allison) (Entered: 08/01/2018) 08/01/2018 23 NOTICE of Appearance by Anne Harden Tindall on behalf of PROTECT DEMOCRACY PROJECT, INC. (Tindall, Anne) (Entered: 08/01/2018) 08/23/2018 24 STATUS REPORT by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE. (Attachments: # 1 Exhibit 1, # 2 Text of Proposed Order)(Schaefer, Daniel) (Entered: 08/23/2018) 08/24/2018 25 NOTICE of Agreement by PROTECT DEMOCRACY PROJECT, INC. re 24 Status Report (Tindall, Anne) (Entered: 08/24/2018) 08/29/2018 MINUTE ORDER: Upon consideration of 24 defendants' status report, 25 plaintiff's notice of agreement thereto, and the entire record herein, it is hereby ORDERED that the parties shall submit a further joint status report by not later than Monday, October 22, 2018. Signed by Judge John D. Bates on 8/29/2018 (lcjdb1) (Entered: 08/29/2018) 08/31/2018 Set/Reset Deadlines: Joint Status Report due by 10/22/2018. (tb) (Entered: 08/31/2018) 10/22/2018 26 Joint STATUS REPORT by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE. (Attachments: # 1 Text of Proposed Order)(Schaefer, Daniel) (Entered: 10/22/2018) 10/23/2018 MINUTE ORDER: Upon consideration of 26 the parties' joint status report, and the entire record herein, it is hereby ORDERED that the parties shall submit a further joint status report by not later than Wednesday, January 23, 2019. Signed by Judge John D. Bates on 10/23/18.(lcjdb1) (Entered: 10/23/2018) 10/23/2018 Set/Reset Deadlines: Joint status report due by 1/23/2019. (lcjdb1) Modified on 10/23/2018 (tb). (Entered: 10/23/2018) 01/23/2019 27 Consent MOTION to Stay in Light of Lapse in Appropriations by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE (Schaefer, Daniel) (Entered: 01/23/2019) 01/23/2019 MINUTE ORDER: Upon consideration of 27 defendants' consent motion for a stay of proceedings in light of the ongoing lapse in appropriations, and the entire record herein, it is hereby ORDERED that defendants' motion for a stay is GRANTED; it is further ORDERED that this action is STAYED until appropriations are restored to the Department of Justice, the Department of State, and the Department of Defense; and it is further ORDERED that the parties shall file a joint status report by not later than fourteen days after Congress has restored appropriations. SO ORDERED. Signed by Judge John D. Bates on 1/23/19. (lcjdb1) (Entered: 01/23/2019)