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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

_________________________________________
CITIZENS FOR RESPONSIBILITY AND :
ETHICS IN WASHINGTON :
11 Dupont Circle, N.W. :
Washington, D.C. 20036 :
:
Plaintiff, :
:
v. : No. 1:05cv00806 (RMC)
:
NATIONAL INDIAN GAMING COMMISSION :
1441 L Street, N.W. :
Washington, D.C. 20005 :
:
Defendant. :
__________________________________________ :

JOINT PROPOSED BRIEFING SCHEDULE

Plaintiff Citizens for Responsibility and Ethics in Washington (“CREW”) filed its

complaint in this Freedom of Information Act (“FOIA”) suit on April 22, 2005. On May 23,

2005, Defendant National Indian Gaming Commission (“NIGC”) filed its answer. As set forth

in the Answer, the NIGC has now responded to Plaintiff’s FOIA request, producing certain

documents and withholding others under a claim of exemption. See Answer, ¶27.

At this point, counsel for the parties have conferred regarding a proposed briefing

schedule on the merits of the government’s claims of exemption. Specifically, after consultation,

counsel for the parties propose the following schedule for briefing on cross-motions for summary

judgment:
Defendant’s Motion: September 12, 2005

Plaintiff’s Opposition and Cross-Motion: October 17, 2005

Defendant’s Opposition and Reply: October 31, 2005

Plaintiff’s Reply: November 14, 2005

No scheduling order has yet been entered in this case, and this schedule is proposed in

the interest of advancing the resolution of this case.

WHEREFORE, based on the foregoing, the parties respectfully request that the Court

enter the attached Order setting forth the parties’ proposed briefing schedule on cross-motions

for summary judgment.

Respectfully submitted,

____/s/_____________________
Anne L. Weismann
(D.C. Bar # 298190)
Melanie Sloan
(D.C. Bar # 434584)
Citizens for Responsibility and Ethics
in Washington
11 Dupont Circle, N.W.
Phone: (202) 588-5565
Fax: (202) 588-5020

Attorneys for Plaintiff

PETER D. KEISLER
Assistant Attorney General

KENNETH L. WAINSTEIN
United States Attorney

______/s/________________
2
ELIZABETH J. SHAPIRO
Assistant Branch Director
JEFFREY M. SMITH (Bar No. 467936)
Trial Attorney, Federal Programs Branch
U.S. Department of Justice, Civil Division
20 Massachusetts Ave., N.W., Room 6140
Washington, D.C. 20001
Tel: (202) 514-5751
Fax: (202) 616-8470

Attorneys for Defendants

August 25, 2005