SOGHOIAN v. DEPARTMENT OF JUSTICE

Filing 22

NOTICE of Filing of Full Vaughn Index by DEPARTMENT OF JUSTICE re Set/Reset Deadlines, (Attachments: # 1 Exhibit Vaughn Index for EOUSA (Boseker Declaration), # 2 Exhibit Vaughn Index for DOJ CRM (Cunningham Declaration))(Interrante, John)

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA CHRISTOPHER SOGHOIAN, Plaintiff, v. DEPARTMENT OF JUSTICE, Defendant. ) ) ) ) ) ) ) ) ) ) ) Civil Action No. 11-1080 (ABJ) ECF NOTICE OF FILING OF FULL VAUGHN INDEX Pursuant to the Court’s June 13, 2012 Minute Order, Defendant, Department of Justice, through undersigned counsel, files a full Vaughn “index of documents withheld from plaintiff's (FOIA) request and the exemptions relied upon for doing so.” Id. As indicated in the Court’s Minute Order, Defendant previously filed a Vaughn index with the Declaration of John F. Boseker (EOUSA), but did not file the Vaughn index with the Declaration of John E. Cunningham, III (DOJ CRM). Undersigned counsel did not realize that the Vaughn index referenced in the Cunningham declaration was omitted from the scanned exhibits attached to its motion for summary judgment until the inadvertent omission was brought to counsel’s attention by the Court’s June 13 Minute Order. The documents withheld from plaintiff’s request by DOJ CRM and the exemptions relied on for doing so are discussed in the Cunningham declaration attached to Defendant’s motion for summary judgment. Thus, plaintiff was aware of the bases for the asserted withholdings and exemptions when he filed his response to Defendant’s motion. Plaintiff’s decision not to contest certain withholdings and exemptions therefore should not be affected by the inadvertent omission of the Vaughn index referenced in the Cunningham declaration. Respectfully submitted, RONALD C. MACHEN JR, DC Bar # 447889 United States Attorney for the District of Columbia DANIEL F. VAN HORN, DC Bar # 924092 Acting Chief, Civil Division By: /s/ JOHN G. INTERRANTE PA Bar # 61373 Senior Litigation Counsel Civil Division 555 4th Street, NW, Room E-4808 Washington, DC 20530 Tel: 202.514.7220 Fax: 202.514.8780 Email: John.Interrante@usdoj.gov 2

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