Case 1:18-cv-00319-CRC Document 22 Filed 02/28/19 Page 1 of 2

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

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) Civil Action No. 1:18-cv-00319 (CRC)
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DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME
Defendant United States Department of Justice (DOJ) moves the Court to extend the
current briefing schedule in this case for a short period of time. Pursuant to Local Rule 7(m),
Defendant consulted with Plaintiff regarding the relief sought in this motion, and Plaintiff does
not oppose the relief requested.
As grounds for the relief requested, DOJ states as follows.
1.

DOJ’s response to Plaintiff’s motion for summary judgment and reply brief in

support of DOJ’s motion for summary judgment regarding the adequacy of its search for records
in this FOIA matter is due today, February 28, 2019.
2.

During final review of the response-reply brief, the Office of Information Policy

(“OIP”), which coordinates responses to FOIA requests made to the Office of the Attorney
General and Office of the Deputy Attorney General, learned this evening of a record responsive
to Plaintiff’s “Guidance FOIA” request that was not identified by OIP’s initial search for records.
In light of this discovery, DOJ requests a short extension of time to produce this record to
Plaintiff and determine whether there are additional responsive records before it files its
response-reply brief.

 Case 1:18-cv-00319-CRC Document 22 Filed 02/28/19 Page 2 of 2

3.

Accordingly, DOJ respectfully requests that the February 28, 2019 deadline for its

response-reply brief be vacated, and that the parties be directed to file a status report, no later
than Wednesday, March 6, 2019, proposing new deadlines for DOJ’s response-reply brief, and
for Plaintiff’s reply brief.

Dated: February 28, 2019

Respectfully submitted,
JOSEPH H. HUNT
Assistant Attorney General
MARCIA BERMAN
Associate Branch Director
/s/ Michael J. Gerardi
Michael J. Gerardi (D.C. Bar No. 1017949)
Trial Attorney
United States Department of Justice
Civil Division, Federal Programs Branch
1100 L St. NW, Rm. 12212
Washington, D.C. 20005
Tel: (202) 616-0680
Fax: (202) 616-8460
E-mail: michael.j.gerardi@usdoj.gov
Attorneys for Defendant