Case: 1:18-cv-00587-CKK As of: 01/03/2019 05:06 AM EST 1 of 3 TYPE I−FOIA U.S. District Court District of Columbia (Washington, DC) CIVIL DOCKET FOR CASE #: 1:18−cv−00587−CKK LYNN v. NATIONAL ARCHIVES AND RECORD Date Filed: 03/16/2018 ADMINISTRATION Jury Demand: None Assigned to: Judge Colleen Kollar−Kotelly Nature of Suit: 895 Freedom of Cause: 05:552 Freedom of Information Act Information Act Jurisdiction: U.S. Government Defendant Plaintiff KATALIN KADAR LYNN represented by Mark Steven Zaid LAW OFFICES OF MARK S. ZAID, P.C. 1250 Connecticut Avenue, NW Suite 200 Washington, DC 20036 (202) 454−2809 Fax: (202) 330−5610 Email: [email protected] ATTORNEY TO BE NOTICED Bradley Prescott Moss LAW OFFICES OF MARK S. ZAID, P.C. 1250 Connecticut Avenue, NW Suite 200 Washington, DC 20036 (202) 907−7945 Fax: (202) 330−5610 Email: [email protected] ATTORNEY TO BE NOTICED V. Defendant NATIONAL ARCHIVES AND represented by Fred Elmore Haynes RECORD ADMINISTRATION U.S. ATTORNEY'S OFFICE FOR THE ` DISTRICT OF COLUMBIA 555 Fourth Street, NW Washington, DC 20530 (202) 252−2550 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED Date Filed # Docket Text 03/16/2018 1 COMPLAINT against NATIONAL ARCHIVES AND RECORD ADMINISTRATION ( Filing fee $ 400 receipt number 0090−5377118) filed by KATALIN KADAR LYNN. (Attachments: # 1 Civil Cover Sheet, # 2 Summons NARA, # 3 Summons USADC, # 4 Summons USAG)(Moss, Bradley) (Entered: 03/16/2018) 03/16/2018 Case Assigned to Judge Colleen Kollar−Kotelly. (zmd) (Entered: 03/19/2018) 03/20/2018 2 SUMMONS (3) Issued Electronically as to NATIONAL ARCHIVES AND RECORD ADMINISTRATION, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent) (zmd) (Entered: 03/20/2018) Case: 1:18-cv-00587-CKK As of: 01/03/2019 05:06 AM EST 2 of 3 03/20/2018 3 ORDER ESTABLISHING PROCEDURES FOR CASES ASSIGNED TO JUDGE COLLEEN KOLLAR−KOTELLY. Signed by Judge Colleen Kollar−Kotelly on 03/20/2018. (DM) (Entered: 03/20/2018) 04/03/2018 4 RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 3/28/2018. Answer due for ALL FEDERAL DEFENDANTS by 4/27/2018. (Attachments: # 1 Exhibit USADC receipt)(Moss, Bradley) (Entered: 04/03/2018) 04/27/2018 5 ANSWER to Complaint by NATIONAL ARCHIVES AND RECORD ADMINISTRATION.(Haynes, Fred) (Entered: 04/27/2018) 04/27/2018 6 ORDER. The parties shall MEET AND CONFER and file a Joint Status Report proposing a schedule for proceeding in this matter by no later than MAY 18, 2018. Signed by Judge Colleen Kollar−Kotelly on 4/27/2018. (lcckk3) (Entered: 04/27/2018) 05/18/2018 7 PROPOSED BRIEFING SCHEDULE by NATIONAL ARCHIVES AND RECORD ADMINISTRATION. (Haynes, Fred) (Entered: 05/18/2018) 05/21/2018 8 SCHEDULING AND PROCEDURES ORDER. Signed by Judge Colleen Kollar−Kotelly on 5/21/2018. (lcckk3) (Entered: 05/21/2018) 05/21/2018 Set/Reset Deadlines: Plaintiff Cross Motion due by 8/16/2018. Response to Cross Motion due by 9/14/2018. Reply to Cross Motion due by 10/15/2018. Defendant's Summary Judgment Motion due by 7/16/2018. Response to Motion for Summary Judgment due by 8/16/2018. Reply to Motion for Summary Judgment due by 9/14/2018. (dot) (Entered: 07/09/2018) 07/03/2018 9 Consent MOTION for Extension of Time to File Defendant's Motion for Summary Judgment by NATIONAL ARCHIVES AND RECORD ADMINISTRATION (Haynes, Fred) (Entered: 07/03/2018) 07/09/2018 MINUTE ORDER. The Court is in receipt of Defendant's 9 Consent Motion for an Extension of Time to File Defendant's Summary Judgment Motion. Defendant requests a two−week extension of time to file its Summary Judgment Motion because additional time is needed to prepare a declaration from the CIA concerning the classified nature of the records at issue in this case. Plaintiff consents to this request. Defendant's Motion is GRANTED. Defendant shall file its Motion for Summary Judgment by no later than JULY 30, 2018. Plaintiff shall file her opposition to Defendant's Summary Judgment Motion, and her Cross−Motion for Summary Judgment, by no later than AUGUST 30, 2018. Defendant shall file its reply in support of its Motion for Summary Judgment, and its opposition to Plaintiff's Motion for Summary Judgment, by no later than SEPTEMBER 28, 2018. Plaintiff shall file her reply in support of her Motion for Summary Judgment by no later than OCTOBER 29, 2018. Signed by Judge Colleen Kollar−Kotelly on 7/9/2018. (lcckk3) (Entered: 07/09/2018) 07/09/2018 Set/Reset Deadlines: Defendant shall file its Motion for Summary Judgment by no later than 7/30/2018. Plaintiff shall file her opposition to Defendant's Summary Judgment Motion, and her Cross−Motion for Summary Judgment, by no later than 8/30/2018. Defendant shall file its reply in support of its Motion for Summary Judgment, and its opposition to Plaintiff's Motion for Summary Judgment, by no later than 9/28/2018. Plaintiff shall file her reply in support of her Motion for Summary Judgment by no later than 10/29/2018. (kt) (Entered: 07/09/2018) 07/24/2018 10 Consent MOTION for Extension of Time to File Defendant's Motion for Summary Judgment by NATIONAL ARCHIVES AND RECORD ADMINISTRATION (Haynes, Fred) (Entered: 07/24/2018) 07/26/2018 MINUTE ORDER. The Court is in receipt of Defendant's 10 Consent Motion for a Brief Further Extension of Time to File Defendant's Summary Judgment Motion. Defendant requests a ten−day extension of time to file its Summary Judgment Motion because additional time is needed for defense counsel to receive declarations from the National Archives and the CIA, and because defense counsel is busy with other matters. This is the second request for an extension of this deadline. Plaintiff consents. Defendant's Motion is GRANTED. Defendant shall file its Motion for Summary Judgment by no later than AUGUST 9, 2018. Plaintiff shall file her opposition to Defendant's Summary Judgment Motion, and her Cross−Motion for Summary Case: 1:18-cv-00587-CKK As of: 01/03/2019 05:06 AM EST 3 of 3 Judgment, by no later than SEPTEMBER 10, 2018. Defendant shall file its reply in support of its Motion for Summary Judgment, and its opposition to Plaintiff's Motion for Summary Judgment, by no later than OCTOBER 9, 2018. Plaintiff shall file her reply in support of her Motion for Summary Judgment by no later than NOVEMBER 8, 2018. Signed by Judge Colleen Kollar−Kotelly on 7/26/2018. (lcckk3) (Entered: 07/26/2018) 07/26/2018 Set/Reset Deadlines: Defendant's Summary Judgment Motion due by 8/9/2018. Response to Motion for Summary Judgment due by 9/10/2018. Reply to Motion for Summary Judgment due by 10/9/2018. Plaintiff's Cross Motion due by 9/10/2018. Response to Cross Motions due by 10/9/2018. Reply to Cross Motions due by 11/8/2018. (dot) (Entered: 07/27/2018) 08/09/2018 11 MOTION for Summary Judgment by NATIONAL ARCHIVES AND RECORD ADMINISTRATION (Attachments: # 1 Exhibit A − Mengel Declaration (NARA), # 2 Exhibit Exhibits to Mengel Declaration, # 3 Exhibit B − Shiner Declaration (CIA))(Haynes, Fred) (Entered: 08/09/2018) 09/10/2018 12 Memorandum in opposition to re 11 MOTION for Summary Judgment filed by KATALIN KADAR LYNN. (Attachments: # 1 Statement of Facts Response, # 2 Exhibit 1 − Moss Declaration, # 3 Text of Proposed Order)(Moss, Bradley) (Entered: 09/10/2018) 10/02/2018 13 Consent MOTION for Extension of Time to File Response/Reply as to 11 MOTION for Summary Judgment by NATIONAL ARCHIVES AND RECORD ADMINISTRATION (Haynes, Fred) (Entered: 10/02/2018) 10/03/2018 MINUTE ORDER. The Court is in receipt of Defendant's 13 Consent Motion for an Extension of Time to File Defendant's Reply Memorandum in Support of its Summary Judgment Motion. Defendant's Reply is currently due October 9, 2018. Defendant requests a ten−day extension of time to file its Reply because unanticipated emergency litigation commitments arose, leaving insufficient time to work on the Reply in this case. Defendant's Motion is GRANTED. Defendant shall file its Reply Memorandum in Support of its Summary Judgment Motion by no later than OCTOBER 19, 2018. Signed by Judge Colleen Kollar−Kotelly on 10−3−2018. (lcckk3) (Entered: 10/03/2018) 10/03/2018 Set/Reset Deadlines: Defendant's Reply to Motion for Summary Judgment due by 10/19/2018. (dot) (Entered: 10/03/2018) 10/18/2018 14 REPLY to opposition to motion re 11 MOTION for Summary Judgment filed by NATIONAL ARCHIVES AND RECORD ADMINISTRATION. (Haynes, Fred) (Entered: 10/18/2018) 01/02/2019 15 NOTICE of Appearance by Mark Steven Zaid on behalf of All Plaintiffs (Zaid, Mark) (Entered: 01/02/2019)