Case 1:05-cv-00806-RMC Document 16 Filed 05/25/2006 Page 1 of 2

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. :
_________________________________________ :

PLAINTIFF’S UNOPPOSED MOTION FOR A STATUS

CONFERENCE AND SUPPORTING MEMORANDUM

Plaintiff Citizens for Responsibility and Ethics in Washington (“CREW”) hereby moves

the Court to hold a status conference for the purpose of determining how to proceed in this

action. As grounds for this motion, Plaintiff states as follows:

1. CREW filed this Freedom of Information Act (“FOIA”) case when the Defendant

National Indian Gaming Commission (“NIGC”) failed to adequately satisfy CREW’s request for

records, made over one year ago on March 21, 2005, relating to the NIGC’s contacts with a

variety of individuals, including now-convicted felons Jack Abramoff and Michael Scanlon and

six specified Indian tribes.

2. In response, Defendant moved for summary judgment, arguing that the agency

conducted an adequate search and properly withheld documents and portions of documents as

exempt from the FOIA. In opposing that motion Plaintiff argued, in part, that the NIGC had

failed to conduct an adequate search.

 Case 1:05-cv-00806-RMC Document 16 Filed 05/25/2006 Page 2 of 2

3. On May 17, 2006, this Court denied defendant’s motion without prejudice, based on

the agency’s failure to demonstrate that it had conducted an adequate search.

4. In light of that opinion and the heightened public interest in the unfolding scandal

involving Jack Abramoff, Michael Scanlon, and their efforts to influence agency decision-

making on matters related to Indian gaming – the subject of CREW’s FOIA request – CREW

respectfully requests that the Court hold a status conference to decide the best and most

expeditious way to proceed. In this way the Court can ascertain what issues remain and the best

process for their resolution. Defendant’s counsel has authorized Plaintiff to represent that

Defendant does not oppose this motion.

CONCLUSION

Wherefore, for the foregoing reasons, Plaintiff respectfully requests that this motion be

granted.

Respectfully submitted,

___/s/________________________
Anne L. Weismann
(D.C. Bar No. 298190)
Melanie Sloan
(D.C. Bar No. 434584)
Citizens for Responsibility and
Ethics in Washington
1400 Eye Street, N.W., Suite 450
Washington, D.C. 20036
Phone: (202) 408-5565
Fax: (202) 588-5020

Attorneys for Plaintiff

Dated: May 25, 2006