Case 1:16-cv-00461-ABJ Document 15 Filed 05/09/16 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA
____________________________________
)
REPUBLICAN NATIONAL
)
COMMITTEE,
)
)
Plaintiff,
)
)
v.
)
Case No. 1:16-CV-461 (ABJ)
)
UNITED STATES DEPARTMENT OF
)
STATE,
)
)
Defendant.
)
____________________________________)
PLAINTIFFS RESPONSE TO MOTION FOR EXTENSION OF TIME TO FILE
PRODUCTION SCHEDULE OR DISPOSITIVE MOTION
On May 6, 2016, Defendant filed a Motion for Extension of Time to File Production
Schedule or Dispositive Motion (Motion for Extension). ECF Dckt. No. 14. The Motion for
Extension requests an extension of time to until May 23, 2016 to file a dispositive motion or
report setting forth the schedule for completion of its production of documents. The length of
the extension is unnecessarily long, and Plaintiff submits that an extension of time until May 16,
2016 would be appropriate.
Plaintiff and the State Department have engaged, and continue to engage, in discussions
regarding the scope of Plaintiffs FOIA requests. Through those discussions, some issues have
been resolved. Specifically, with respect to the following two FOIA requests in this case, the
State Department has represented that no responsive records exist:

Any and all emails sent to, or sent by, Bryan Pagliano for the time period May 1, 2009
through February 1, 2013.

Case 1:16-cv-00461-ABJ Document 15 Filed 05/09/16 Page 2 of 4

Any and all text messages or BlackBerry Messenger messages (BBMs) sent to, or sent
by, Hillary Clinton for the time period May 1, 2009 through February 1, 2013.

Accordingly, additional discussion on a production schedule with respect to these two requests is
not needed, assuming the accuracy of the State Departments representation.
Plaintiff and the State Department have discussed the FOIA requests regarding emails for
Cheryl Mills, Jacob Sullivan, and Patrick Kennedy. Those discussions are advanced and
Plaintiff has proposed methods through which the requests can be narrowed and prioritized. As a
result, the State Department should be able to set forth a schedule for the completion of its
production or a proposed briefing schedule for a dispositive motion by May 16, 2016.
Accordingly, Plaintiff respectfully requests that the Court grant a more limited extension
for State Department to file a dispositive motion or a report setting forth a schedule of documents
and set the deadline for May 16, 2016.
Dated: May 9, 2016

Respectfully submitted,
/s/ Laura E. Sierra
LAURA SIERRA (D.C. Bar No. 984944)
laura.sierra@alston.com
EDWARD T. KANG (D.C. Bar No. 1011251)
edward.kang@alston.com
KELLEY C. BARNABDY (D.C. Bar No. 998757)
kelley.barnaby@alston.com
ALSTON & BIRD LLP
950 F. Street NW
Washington, D.C. 20004
Telephone: (202) 239-3300
Counsel for Plaintiff Republican National
Committee

Case 1:16-cv-00461-ABJ Document 15 Filed 05/09/16 Page 3 of 4

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA
)
REPUBLICAN NATIONAL
)
COMMITTEE,
)
)
Plaintiff,
)
)
v.
)
Case No. 1:16-CV-461 (ABJ)
)
UNITED STATES DEPARTMENT OF
)
STATE,
)
)
Defendant.
)
____________________________________)
PROPOSED ORDER
Upon consideration of Defendants Motion for Extension of Time to File a Production
Schedule or Dispositive Motion and Plaintiffs Response, it is hereby
ORDERED that the motion is GRANTED as modified; and it is
FURTHER ORDERED that the State Department shall have until May 16, 2016 to file a
proposed production schedule or a proposed briefing schedule for a dispositive motion.
SO ORDERED.
Dated: ________________

______________________________
AMY BERMAN JACKSON
United States District Judge

Case 1:16-cv-00461-ABJ Document 15 Filed 05/09/16 Page 4 of 4

CERTIFICATE OF SERVICE
I hereby certify that on this date, May 9, 2016, I electronically filed the foregoing with
the clerk of the Court using the CM/ECF system, causing a copy of the foregoing to be served on
all counsel appearing in this matter.
/s/ Laura E. Sierra
Laura E. Sierra