Brennan Center For Justice At New York University School Of Law v. United States Department of State

Filing 87

ORDER granting 86 Letter Motion to Adjourn Conference. The conference currently scheduled for September 20, 2022 will instead take place on September 21, 2022 at 2:30 p.m. by telephone. The parties are directed to dial 888-363-4749 to participa te, and to enter the access code 6212642. The press and public may obtain access to the telephone conference by dialing the same number and using the same access code. The Court is holding multiple telephone conferences on this date. The parties sh ould call in at the scheduled time and wait on the line for their case to be called. At that time, the Court will un-mute the parties' lines. One day before the conference, the parties must email [e-mail] and Gardep [e-mail] with the phone numbers that the parties will be using to dial into the conference so that the Court knows which numbers to un-mute. The email should include the case name and case number in the subject line. SO ORDERED.. (Signed by Judge Paul G. Gardephe on 9/19/2022) Telephone Conference set for 9/21/2022 at 02:30 PM before Judge Paul G. Gardephe. (ks)

Case 1:17-cv-07520-PGG Document 87 Filed 09/19/22 Page 1 of 2

September 15, 2022

Via ECF
The Honorable Paul G. Gardephe
United States District Judge
Thurgood Marshall United States Courthouse
40 Foley Square
New York, NY 10007
Re:

Brennan Center for Justice at New York University School of
Law v. United States Department of State, 17 Civ. 7520 (PGG)

Dear Judge Gardephe:
I am lead counsel for Plaintiff Brennan Center for Justice at New York University School
of Law (“Brennan Center”) in the above-captioned Freedom of Information Act litigation.
On September 13, the Court reset the conference in this case from September 16 to
September 20. Due to a conflicting professional obligation, explained in further detail below, I
respectfully request that the conference be rescheduled for one of the following dates: Friday,
September 23, Wednesday, September 28, or Thursday, September 29. I have spoken with
counsel for the defendant, AUSA Christopher Connolly, and he consents to the continuance and
is available on the suggested dates. In the alternative, if the Court is willing to conduct the
conference by teleconference or a video conference, I could appear at the time currently
scheduled on September 20 (or any other time on the 20th before 3 pm), or on the following
additional dates on which both Mr. Connolly and I are available: all the above-listed dates;
Wednesday, September 21; before noon on Thursday, September 22; after 3 pm on Monday,
September 26; or before 3 pm on Tuesday, September 27.
The conflict arises from my representation of a lawyer who is charged by District of
Columbia Disciplinary Counsel with violations of D.C. Rules of Professional Conduct. The
matter is now before the D. C. Board on Professional Responsibility, which several months ago
scheduled oral argument for September 22. I believe that my preparation for the argument,
which will require most of my attention in the days immediately preceding September 22, would
be substantially impaired by devoting the time required to make a trip to New York for a
conference on the 20th. I hope that the several alternatives that Mr. Connolly and I have offered
will make it possible to reschedule the conference.
Thank you for your consideration of this matter.

Case 1:17-cv-07520-PGG Document 87 Filed 09/19/22 Page 2 of 2

The Honorable Paul G. Gardephe
September 15, 2022
Page 2

Sincerely,

/s/ Mark H. Lynch
Mark H. Lynch
Covington & Burling LLP
One City Center
850 Tenth Street, NW
Washington, DC 20001-4956
[phone]
[e-mail]
Attorney for Plaintiff Brennan
Center for Justice at New York
University School of Law
cc: Counsel of Record (by ECF)

Memo Endorsed: The conference currently scheduled for September 20, 2022 will instead take
place on September 21, 2022 at 2:30 p.m. by telephone. The parties are directed to dial
888-363-4749 to participate, and to enter the access code 6212642. The press and public may obtain
access to the telephone conference by dialing the same number and using the same access code. The
Court is holding multiple telephone conferences on this date. The parties should call in at the
scheduled time and wait on the line for their case to be called. At that time, the Court will un-mute
the parties’ lines. One day before the conference, the parties must email
[e-mail] and [e-mail] with the
phone numbers that the parties will be using to dial into the conference so that the Court knows
which numbers to un-mute. The email should include the case name and case number in the subject
line.
Dated: September 19, 2022