Case 1:17-cv-01247-TSC Document 10 Filed 09/15/17 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
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Plaintiff,
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v.
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U.S. DEPARTMENT OF EDUCATION )
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Defendant.
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AMERICAN OVERSIGHT

Civil Action No. 17-1247 (TSC)

DEFENDANT’S MOTION FOR EXTENSION OF TIME

Defendant, through Counsel, pursuant to Rule 6(b) of the Federal Rules of Civil
Procedure, respectfully moves this Court for an Extension of Time up to and including October
4, 2017 to respond to Plaintiff’s Complaint.
Despite best efforts, Defendant is requesting additional time to fully respond to Plaintiff’s
complaint. First, all responsive documents have been produced to Plaintiff in FOIA No. 1701480-F. The remaining documents in the second FOIA, Request No. 17-01479-F, are
substantially completed. Some of these documents are being reviewed internally and should be
ready for production on
September 20, 2017. The final three calendars are at the White House for review and the
response to the Agency on these final three calendars should hopefully be produced before
October 4, 2017.
Specifically, the responsive documents that have been released are set forth below and
those expected responsive documents should be released in the time frame noted.

 Case 1:17-cv-01247-TSC Document 10 Filed 09/15/17 Page 2 of 4

For FOIA Request No. 17-1480-F, (that was Production II):
Office of the Secretary - 105 pages
Office of the General Counsel – 5 pages
TOTAL FOR 01480 Production II (excluding attachments) – 110 pages
For FOIA Request No. 17-01479-F (Production I):
Breeding- 47 pages
Ferguson – 40 pages
Ham – 20 pages
Reynolds – 19 pages
St. Pierre – 94 pages
Oberlies – 19 pages
Whitaker – 22 pages
McLaughlin - 108 pages
Hudson – 22 pages
Chamberlain – 14 pages
TOTAL FOR PRODUCTION I – 411 pages (not including attachments)
For FOIA Request No. 17-01479-F (Production II):
Brickman – 96 pages
Stracke – 92 pages
Riemer – 30 pages
Shaheen – 14 pages
Kossack - 31 pages
Toner – 89 pages

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 Case 1:17-cv-01247-TSC Document 10 Filed 09/15/17 Page 3 of 4

Smith – 126 pages
Lee – 340 pages
Davis – 51 pages
Neuman – 50 pages
TOTAL FOR PRODUCTION II (excluding 01480 which is listed above) – 919 pages (not
including attachments)
Scheduled for Release in Production III:
Eitel – 117 pages
Simmons – 102 pages
Goad – 72 pages
Delahunty – 110 pages
Botel – 166 pages
Manning – 58 pages
Holden – 103 pages
Bailey – 141 pages
TOTAL SCHEDULED FOR PRODUCTION III (excluding attachments) – 869 pages
Scheduled for Production IV (these are with White House for equities issues):
DeVos – 326 pages
Venable – 254 pages
Ventimiglia – 123 pages
TOTAL SCHEDULED FOR PRODUCTION IV (excluding attachments) – 705 pages
This request for enlargement is made in good faith and is no way designed to delay the
proceedings.

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 Case 1:17-cv-01247-TSC Document 10 Filed 09/15/17 Page 4 of 4

Respectfully submitted,
CHANNING D. PHILLIPS., D.C. Bar #415793
United States Attorney for the District of Columbia

DANIEL F. VAN HORN, D.C. Bar #924092
Chief, Civil Division

By: /s/ Wyneva Johnson_______________
WYNEVA JOHNSON, D.C. Bar # 278515
Assistant United States Attorney
555 4th Street, N.W.
Washington, D.C. 20530
Tel: (202) 252-2518
Wyneva.johnson@usdoj.gov

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 Case 1:17-cv-01247-TSC Document 10-1 Filed 09/15/17 Page 1 of 1

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN OVERSIGHT,
Plaintiff,
v.

Civil Action No. 17-1247 (TSC)

U.S. DEPARTMENT OF EDUCATION,
Defendant.
ORDER
Upon consideration of Defendant’s Motion for an Extension of Time, any opposition
thereto and the entire record herein, it is ORDERED that Defendant’s Motion for an
Extension be and is hereby GRANTED, and Defendant shall have up to and including
October 4, 2017 to respond to Plaintiff’s Complaint.
SO ORDERED.

__________________________
U.S. DISTRICT JUDGE