CITIZENS FOR RESPONSIBILITY AND ETHICS IN WASHINGTON v. NATIONAL ARCHIVES AND RECORDS ADMINISTRATION

Filing 18

Joint MOTION for Correction of Court Order and Deferral of Compliance Date re 16 Order,, 17 Memorandum & Opinion by NATIONAL ARCHIVES AND RECORDS ADMINISTRATION (Simpson, W.)

CITIZENS FOR RESPONSIBILITY AND ETHICS IN WASHINGTON v. NATIONAL ARCHIVES AND RECORDS ADMINISTRATION Doc. 18

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

CITIZENS FOR RESPONSIBILITY AND ETHICS IN WASHINGTON, Plaintiff, v. NATIONAL ARCHIVES AND RECORDS ADMINISTRATION, Defendant.

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CIVIL ACTION NO. 1:07-cv-00048-RBW

JOINT MOTION FOR CORRECTION OF COURT ORDER AND DEFERRAL OF COMPLIANCE DATE All parties, by their undersigned counsel, hereby respectfully request the correction of certain issues in relation to this Court's Order and Memorandum Opinion of September 29, 2008 [16, 17], as follows: 1. The Order does not address the status of four documents whose withholding or partial withholding the plaintiff continues to contest -- specifically, Documents 18a, 46, 49, and 54. 2. Among the documents that the Order requires the defendant to submit for in camera review is Document 15a, whose withholding the plaintiff no longer contests. Accordingly, the parties respectfully request the following: · That the Order and Memorandum Opinion of September 29, 2008, be amended (a) to address, as the Court may see fit, the parties' dispute regarding Documents 18a, 46, 49, and 54, and (b) to omit Document 15a from the documents to be submitted for in camera review; and

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That defendant's deadline to comply with the Order be deferred until (a) 30 days after these matters are resolved, if the Court orders the submission of additional support for defendant's withholding of any of the documents listed in paragraph 1 above, or (b) 10 days after these matters are resolved, if the Court does not order the submission of any such additional support. Respectfully submitted,

/s/ Anne L. Weismann _____________________________________ ANNE L. WEISMANN, D.C. Bar No. 298190 MELANIE SLOAN, D.C. Bar No. 434584 Citizens for Responsibility and Ethics in Washington 1400 Eye Street, N.W., Suite 450 Washington, D.C. 20005 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Dated: October 14, 2008 COUNSEL FOR PLAINTIFF

GREGORY G. KATSAS Assistant Attorney General JEFFREY A. TAYLOR United States Attorney ELIZABETH J. SHAPIRO, D.C. Bar 418925 Assistant Director JOHN R. TYLER, D.C. Bar 297713 Senior Trial Counsel /s/ W. Scott Simpson W. SCOTT SIMPSON, Va. Bar 27487 Senior Trial Counsel Attorneys, Department of Justice Civil Division, Room 7210 Post Office Box 883 Washington, D.C. 20044 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Dated: October 14, 2008 COUNSEL FOR DEFENDANT

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