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CITIZENS UNITED,
Plaintiff,
Defendant.
respectfully moves this Court, pursuant to Federal Rule of Civil Procedure 6(b), for a 60-day
first extension request in this matter. The grounds for this motion are set forth below and a
Plaintiff Citizens United brought an action against State under the Freedom of
Information Act, 5 U.S.C. § 552, to compel State to conduct a search records responsive to its
FOIA request and to produce all responsive non-exempt records by a date certain. Compl., ECF
No. 1 (May 30, 2018). State rejected the request as improper because it failed to reasonably
describe the records sought. Id. ¶ 11. Citizens United claims that State’s refusal to process the
request and conduct a search violated FOIA. Id. ¶¶ 12–13. Citizens United seeks injunctive,
Based on the date of service of the summons and complaint on the U.S. Attorney’s
Office, Defendant’s response is due on July 11, 2018. Upon further review, State has determined
that this request should not have been rejected for failing to reasonably describe the records and
that it should instead be processed. State requests that the Court extend the deadline for the
filing of the answer by 60 days, until September 10, 2018, to provide State time needed to
process and further respond to the request. State’s decision to process the request moots at least
some, if not all, of the claims, and may also avoid the need for further litigation.
Defendant has conferred with Plaintiff concerning the requested enlargement. Plaintiff,
For the foregoing reasons, and for good cause shown, Defendant respectfully requests
that the Court extend the time for it to file its initial response to the complaint until September
10, 2018.
JESSIE K. LIU
D.C. Bar 472845
United States Attorney