Case 1:18-cr-00032-DLF Document 76 Filed 11/27/18 Page 1 of 2

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v.
Crim. No. 18-cr-32 (DLF)
INTERNET RESEARCH AGENCY, ET AL.,
Defendants.

JOINT MOTION REQUESTING SCHEDULING ORDER
The United States of America and defendant Concord Management and Consulting, LLC
(“Concord”) hereby respond to the Court’s Order requesting a schedule for further proceedings
and for briefing on any outstanding discovery issues as follows.
Defense counsel has advised that the defendant intends to file a motion pursuant to
Paragraph 11 of the Protective Order (Dkt. 42-1) seeking the Court’s approval to disclose
discovery designated as Sensitive by the government to officers and employees of Concord. The
parties have conferred on a briefing schedule for this motion, as set forth in the attached
proposed order. Both parties anticipate filing additional pretrial motions. However, because the
defense has represented to the government that the resolution of this motion will significantly
affect the defense position with respect to how it can proceed, the parties request that the Court
refrain from scheduling further proceedings in this matter until this motion is decided.
The parties further request that the Court exclude the time from November 15, 2018, the
date of the Court’s ruling on the defendant’s most recent motion to dismiss, to December 21,
2018, the proposed date of the defendant’s filing of its motion, for purposes of the Speedy Trial
Act, 18 U.S.C. § 3161 et seq. This exclusion is warranted under 18 U.S.C. § 3162(h)(7)(A) on
the ground that the ends of justice served by a continuance outweigh the best interest of the

 Case 1:18-cr-00032-DLF Document 76 Filed 11/27/18 Page 2 of 2

public and the defendant in a speedy trial. In particular, this case is unusually complex due to the
nature of the prosecution, the possibility of novel questions of fact or law, and the voluminous
discovery at issue. 18 U.S.C. § 3162(h)(7)(B).
Respectfully submitted,
ROBERT S. MUELLER, III
Special Counsel

CONCORD MANAGEMENT
AND CONSULTING LLC

By: /s/
Michael R. Dreeben
Jeannie S. Rhee
Adam C. Jed
950 Pennsylvania Avenue NW
Washington, D.C. 20530
Telephone: (202) 616-0800

By: /s/ Eric. A. Dubelier
Eric A. Dubelier (D.C. Bar No. 419412)
Katherine J. Seikaly (D.C. Bar. No. 498641)
Reed Smith LLP
Suite 1000 – East Tower
Washington, D.C. 20005-3373
Telephone: (202) 414-9200
Fax: (202) 414-9299
dubelier@reedsmith.com
seikaly@reedsmith.com

JOHN C. DEMERS
Assistant Attorney General
for National Security

James C. Martin*
Colin E. Wrabley*
Reed Smith LLP
225 Fifth Avenue
Pittsburgh, PA 15222-2716
Telephone: (412) 288-3131
Fax: (412) 288-3063
jcmartin@reedsmith.com
cwrabley@reedsmith.com

By: /s/
Heather N. Alpino
U.S. Department of Justice
National Security Division
950 Pennsylvania Ave. NW
Washington, D.C. 20530
Telephone: (202) 514-2000

JESSIE K. LIU
United States Attorney
By: /s/
Jonathan Kravis
Deborah Curtis
Kathryn Rakoczy
555 Fourth Street NW
Washington D.C. 20530
Telephone: (202) 252-6886

* Admitted Pro Hac Vice

 Case 1:18-cr-00032-DLF Document 76-1 Filed 11/27/18 Page 1 of 2

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v.
Crim. No. 18-cr-32 (DLF)
INTERNET RESEARCH AGENCY, ET AL.,
Defendants.

ORDER
Having considered the parties’ Joint Motion Requesting a Scheduling Order, it is
ORDERED that the motion is GRANTED as follows:
(1) The defendant, Concord Management and Consulting, LLC, shall file its motion to
disclose discovery designated as Sensitive by the government to officers and
employees of Concord on or before December 21, 2018;
(2) The government shall file its opposition on or before January 30, 2019;
(3) The defendant shall file its reply on or before February 20, 2019.
Further, the Court finds that the ends of justice are served by the granting of a
continuance pursuant to 18 U.S.C. § 3161(h)(7)(A) and outweigh the best interest of the public
and the defendant in a speedy trial. Specifically, as described by the parties in their joint motion,
this case is unusual and complex due to the nature of the prosecution, the possibility of novel
questions of fact or law, and the voluminous discovery at issue. See 18 U.S.C. §
3161(h)(7)(B)(ii). Accordingly, it is ORDERED that the period of November 15, 2018 to
December 21, 2018 is excluded for purposes of Speedy Trial Act calculations.

 Case 1:18-cr-00032-DLF Document 76-1 Filed 11/27/18 Page 2 of 2

SO ORDERED.

Date:
DABNEY L. FRIEDRICH
United States District Judge