Professional Documents
Culture Documents
Contrary to Plaintiffs statements, the undersigned never said to Plaintiff that that the
burden of locating any documents missing from the FOIA Response would fall on Plaintiff[.]
(Pltffs letter at 2). Rather, the undersigned stated that the documents included in the
discretionary release were available on PACER and the full set of documents available on
PACER was not part of the discretionary release because not all of those documents were located
in USAO-DCs files and not all of those documents relate specifically to Daniel Choi, who was
only one defendant in a multi-defendant case. Further, the undersigned sought clarification as to
which portions of the non-responsive discretionary release that Plaintiff felt were missing and
offered to provide, as a courtesy, the two documents Plaintiff identified. However, Plaintiff
declined the offer.
By September 25, 2015, DOJ file and serve its motion for summary judgment;
By October 23, 2015, Plaintiff file and serve opposition and any cross-motion;
and
By November 11, 2015, DOJ file and serve a reply and opposition to any crossmotion.
DOJ is prepared to discuss these issues with the Court on September 16, 2015. Thank
you for Your Honors attention to this matter.
Respectfully submitted,
KELLY T. CURRIE
Acting United States Attorney
By:
cc:
s/Rukhsanah L. Singh
RUKHSANAH L. SINGH
Assistant U.S. Attorney
(718) 254-6498
rukhsanah.singh@usdoj.gov