Knight First Amendment Institute at Columbia University et al v. Trump et al

Filing 29

ORDER: terminating 28 Letter Motion for Conference. The parties proposed schedule and page limits are acceptable to the Court. Motion due by 10/13/2017. Response due by 11/13/2017. Cross Motion due by 11/3/2017. Reply due by 11/22/2017. (Signed by Judge Naomi Reice Buchwald on 9/26/2017) (ap)

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Case 1:17-cv-05205-NRB Document 29 Filed 09/26/17 Page 1 of 3 Case 1:17-cv-05205-NRB Document 28 Filed 09/25/17 Page 1of3 • • . . -· - ·----·- ·- -·----·- ....... ,.,~ - t September 25, 2017 Via ECF and by Fax The Hon. Naomi Reice Buchwald United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 .. lk.(J~~~ ..x/~1£.«k ~/,""'7'~ t:V2e_ .a/~~ .m .7LL- ~. L.~~£61~ ~t?l.4,2.G/7 Re: Knight First Amendment Institute at Columbia University, et al. v. Trump, et al., 1 No. 17-cv-5205 (NRB) Dear Judge Buchwald, The parties in the above-referenced matter write to update the Court on the status of their negotiations following the August 15, 2017, telephone conference with the Court and to propose a schedule for further proceedings in the case. At that conference, the Court noted that it might be possible for the parties to reach agreement on a set of stipulated facts that would govern any forthcoming dispositive motions. Consistent with that suggestion, the parties have reached agreement on the attached set of stipulated facts that would permit both sides to move for summary judgment without the need for discovery or briefing on preliminary motions, including plaintiffs proposed motion for preliminary relief. The parties have agreed to stipulate to the attached facts for the duration of this litigation only; the facts are not intended to bind the parties in future cases. In light of the stipulated facts and the agreement of the parties to proceed to summary judgment, the parties jointly propose the following schedule for further proceedings: Defendants' Motion for Summary Judgment Plaintiffs' Opposition and Cross-Motion Defendants' Reply and Opposition Plaintiffs' Reply October 13, 2017 November 3, 2017 November 13, 2017 November 22, 2017 Should the Court accept this proposal, the parties request leave to file memoranda of law and reply memoranda within the following page limits: ' Sarah Huckabee Sanders, White House Press Secretary, and Hope Hicks, White House Communications Director, are substituted for Sean Spicer as defendants in this case pursuant to Federal Rule of Civil Procedure 25(d). Case 1:17-cv-05205-NRB Document 29 Filed 09/26/17 Page 2 of 3 Case 1:17-cv-05205-NRB Document 28 Filed 09/25/17 Page 2 of 3 2 Defendants' Motion for Summary Judgment Plaintiffs' Opposition and Cross-Motion Defendants' Reply and Opposition Plaintiffs' Reply 25 35 25 15 pages pages pages pages In light of the parties' proposal to proceed directly to summary judgment on the basis of the attached stipulated facts, the parties request that the Court stay both the requirement that Defendants file an answer to the Complaint, which otherwise would be due September 29, 2017, and the parties' obligations under Rules 16 and 26, until 30 days after the resolution of any forthcoming dispositive motions. For these reasons, the parties respectfully request that the Court schedule a pre-motion conference to discuss the parties' proposal. Should the Court accept the parties' proposed schedule and page limits, the parties have no further issues to address at a pre-motion conference. Respectfully submitted, Jessica Ring Amunson (pro hac vice) Tassity S. Johnson (pro hac vice) Jenner & Block LLP 1099 New York Avenue, NW, Suite 900 Washington, DC 20001 Isl Jameel Jaffer Jameel Jaffer (JJ-4653) Katherine Fallow (application for admission pending) Alex Abdo (AA-0527) Knight First Amendment Institute at Columbia University 314 Low Library 535 West 116th Street New York, NY 10027 (212) 854-9600 Jam eel .J affer@knightcolumbia.org Counsel for Plaintif.Js CHAD A. READLER Acting Assistant Attorney General ERIC R. WOMACK Assistant Branch Director Isl Michael H. Baer MICHAEL H. BAER DANIEL HALAINEN Trial Attorneys U.S. Department of Justice, Case 1:17-cv-05205-NRB Document 29 Filed 09/26/17 Page 3 of 3 Case 1:17-cv-05205-NRB Document 28 Filed 09/25/17 Page 3 of 3 3 Civil Division, Federal Programs Branch 20 Massachusetts A venue, NW Washington, DC 20530 Telephone: (202) 305-8573 (202) 616-8460 Facsimile: E-mail: Michael.H.Baer@usdoj.gov Counsel for Defendants

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