DOES 1-9 v. DEPARTMENT OF JUSTICE

Filing 32

MOTION to Expedite Discovery by FEDERAL BUREAU OF INVESTIGATION AGENTS ASSOCIATION. (Attachments: # 1 Memorandum in Support, # 2 Exhibit Exhibit A (Revised), # 3 Exhibit Exhibit B, # 4 Text of Proposed Order)(Donovan, Margaret)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
JOHN AND JANE DOES 1-9, et al.,
Plaintiffs,
v.

Civil Action No. 25-0325 (JMC)

DEPARTMENT OF JUSTICE,
Defendant.
FEDERAL BUREAU OF INVESTIGATION
AGENTS ASSOCIATION, et al.,
Plaintiffs,
Civil Action No. 25-0328 (JMC)

v.
DEPARTMENT OF JUSTICE, et al.,
Defendants.

PLAINTIFFS’ REVISED MOTION FOR EXPEDITED DISCOVERY
The above-captioned consolidated Plaintiffs hereby file this motion and accompanying
memorandum for expedited discovery in the above-captioned matter, which is a revision of the
motion filed at ECF No. 20, denied without prejudice to refiling. Plaintiffs respectfully request
Defendants provide discovery within a timeframe that accommodates the preliminary hearing
currently scheduled for March 27, 2025. As explained in the supporting memorandum of law
attached hereto, the requested discovery materials have been narrowed in response to the Court’s
February 28, 2025 Minute Order, are limited in scope, are for good cause, and should be easily
retrievable by the Government. Plaintiffs’ revised discovery requests are attached hereto as
Exhibit A. Plaintiffs’ per-item justification for those requests is attached hereto as Exhibit B.

In accordance with Local Civil Rule 7(m), at 9:00 a.m. on March 5, 2025, the parties met
via videoconference to conduct a meet-and-confer regarding the Plaintiffs’ revised requests.
Following that meeting, Plaintiffs further reduced their revised requests and resubmitted them to
the Government for consideration on March 10, 2025. The Government opposed the revised
disclosures and submitted the following statement: “Defendants oppose Plaintiffs’ revised request
for expedited discovery and intend to file an opposition setting forth the reasons for its opposition
on or before March 18, 2025. In conferring with Plaintiffs on this motion, Defendants understand
that Plaintiffs do not object to this response date.” Plaintiffs do not object to this response date.
WHEREFORE, Plaintiffs respectfully request that the Court enter an order allowing for
such limited expedited discovery, as set forth in the attached Proposed Order.

March 10, 2025
Respectfully submitted,
LAW OFFICE OF MARK S. ZAID, P.C.

CENTER FOR EMPLOYMENT JUSTICE

By:

By:
Pamela M. Keith
PAMELA M. KEITH, D.C. Bar #448421
SCOTT M. LEMPERT, D.C. Bar #1045184
650 Massachusetts Ave., NW, Suite 600
Washington, DC 20001
[phone]
[e-mail]
[e-mail]
Attorneys for John and Janes Does 1-9, et al.
(25-325)

Mark S. Zaid
MARK S. ZAID, D.C. Bar #440532
BRADLEY P. MOSS, D.C. Bar #975905
1250 Connecticut Avenue, NW, Suite 700
Washington, D.C. 20036
[phone]
[e-mail]
[e-mail]
Attorneys for John Does 1,3-4,
Jane Does 1-3 (25-328)

2

STATE DEMOCRACY DEFENDERS FUND

KOSKOFF, KOSKOFF & BIEDER, PC

By:

By:
Margaret Donovan
Christopher Mattei, Bar # 27500 (pro hac vice)
Margaret Donovan, Bar # 31787 (pro hac vice)
350 Fairfield Ave., Suite 501
Bridgeport, CT 06604
[phone]
[e-mail]
[e-mail]
Attorneys for Federal Bureau of Investigation
Agents Association (25-328)

Norman L. Eisen
Norman L. Eisen D.C. Bar # 435051
Pooja Chaudhuri, D.C. Bar # 888314523
600 Pennsylvania Avenue, SE, #15180
Washington, D.C. 20003
[phone]
[e-mail]
[e-mail]
Attorneys for John Does 1,3-4,
Jane Does 1-3 (25-328)

Attorneys for Plaintiffs

3