Case: Protect Democracy Project v. U.S. Department of Homeland Security

Protect Democracy Project v. Department of Homeland Security

Protect Democracy Project v. Department of Homeland Security

Protect Democracy Project v. Department of Homeland Security

The Protect Democracy Project, Inc v. Department of Homeland Security

The Protect Democracy Project, Inc v. Department of Homeland Security

COMPLAINT against PROTECT DEMOCRACY PROJECT, INC. ( Filing fee $ 400 receipt number 0090-5157619) filed by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Summons USAO, # 6 Summons AG, # 7 Summons CBP, # 8 Summons DHS, # 9 Summons OMB, # 10 Summons OPM)(Barnett, Kevin) (Entered: 10/13/2017)

1 Civil Cover Sheet

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2 Exhibit

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3 Exhibit

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4 Exhibit

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5 Summons USAO

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6 Summons AG

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7 Summons CBP

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8 Summons DHS

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9 Summons OMB

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10 Summons OPM

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SUMMONS (6) Issued Electronically as to CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT, U.S. Attorney and U.S. Attorney General (Attachment: # 1 Notice and Consent)(zsb) (Entered: 10/13/2017)

STANDING ORDER: The parties are hereby ORDERED to comply with the directives set out in the attached standing order. See document for details. Signed by Judge Randolph D. Moss on 10/13/17. (lcrdm3, ) (Entered: 10/13/2017)

LCvR 7.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by PROTECT DEMOCRACY PROJECT, INC. (Barnett, Kevin) (Entered: 10/13/2017)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 10/13/2017. Answer due for ALL FEDERAL DEFENDANTS by 11/12/2017. (Barnett, Kevin) (Entered: 10/13/2017)

Case Assigned to Judge Randolph D. Moss. (zsb)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. CUSTOMS AND BORDER PROTECTION served on 10/16/2017; DEPARTMENT OF HOMELAND SECURITY served on 10/16/2017; OFFICE OF MANAGEMENT AND BUDGET served on 10/16/2017; OFFICE OF PERSONNEL MANAGEMENT served on 10/16/2017, RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 10/16/2017. (Barnett, Kevin) (Entered: 10/16/2017)

NOTICE of Appearance by Scott Leeson Sroka on behalf of All Defendants (Sroka, Scott) (Entered: 11/08/2017)

NOTICE of Appearance by Nikhil Vikas Gore on behalf of PROTECT DEMOCRACY PROJECT, INC. (Gore, Nikhil) (Entered: 11/08/2017)

ANSWER to 1 Complaint by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT.(Sroka, Scott) Modified to add link on 11/14/2017 (znmw). (Entered: 11/13/2017)

Set/Reset Hearings: Status Conference set for 1/4/2018, at 10:15 AM, in Courtroom 21, before Judge Randolph D. Moss. (kt)

MINUTE ORDER: The parties are hereby ORDERED to appear for a status conference on January 4, 2018, at 10:15 a.m. in Courtroom 21, to discuss the schedule for further proceedings in this matter. The parties shall confer in advance of the status conference to narrow the issues for discussion. Signed by Judge Randolph D. Moss on 11/13/17. (lcrdm3, )

NOTICE of Appearance by Jennifer H. Saperstein on behalf of PROTECT DEMOCRACY PROJECT, INC. (Saperstein, Jennifer) (Entered: 01/02/2018)

NOTICE OF WITHDRAWAL OF APPEARANCE as to PROTECT DEMOCRACY PROJECT, INC.. Attorney Kevin Travers Barnett terminated. (Barnett, Kevin) (Entered: 01/02/2018)

Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 1/4/2018. Joint Status Report due by 3/3/2018. A further Status Conference is set for 3/13/2018, at 10:00 AM, in Courtroom 21, before Judge Randolph D. Moss. (Court Reporter: Jeff Hook.) (kt)

Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 03/02/2018)

STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 03/12/2018)

Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 3/13/2018. Defendant OPM shall complete its production of documents by by 4/6/2018; The remaining Defendant shall provide Plaintiffs and the Court with a production schedule by 4/13/2018. (Court Reporter: Jeff Hook.) (kt)

Set/Reset Deadlines: Joint Status Report due by 4/27/2018. (kt)

MINUTE ORDER: It is hereby ORDERED that the parties shall submit a joint status report on or before April 27, 2018, identifying the issues remaining in this litigation and proposing a schedule for further proceedings. Signed by Judge Randolph D. Moss on 3/14/18. (lcrdm3, )

STATUS REPORT and Proposed Production Schedule by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT. (Sroka, Scott) (Entered: 04/13/2018)

Joint MOTION for Extension of Time to File Joint Status Report by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT (Sroka, Scott) (Entered: 04/27/2018)

Set/Reset Deadlines: Joint Status Report due by 5/4/2018. (dot)

MINUTE ORDER: Upon consideration of the Joint Motion for Extension of Time 15, it is hereby ORDERED that the motion is GRANTED. The parties shall file a joint status report on or before May 4, 2018. Signed by Judge Randolph D. Moss on 4/27/18. (lcrdm3, )

Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 05/04/2018)

Set/Reset Hearings: Status Conference set for 5/14/2018, at 2:00 PM, in Courtroom 21, before Judge Randolph D. Moss. (kt)

MINUTE ORDER: In light of the parties' Joint Status Report 16, it is hereby ORDERED that the parties shall appear for a status conference on May 14, 2018, at 2:00 p.m. in Courtroom 21. Signed by Judge Randolph D. Moss on 5/7/18. (lcrdm3, )

Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 5/14/2018. Document productions shall proceed as ordered on the record. A further Status Conference is set for 7/6/2018, at 12:30 PM, in Courtroom 21, before Judge Randolph D. Moss. (Court Reporter: Jeff Hook.) (kt)

STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 07/05/2018)

Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 7/6/2018. By 7/10/2018, Department of Homeland Security shall provide Plaintiff with search terms, as stated on the record; By 7/13/2018, but no later than 7/27/2018, the parties shall meet and confer regarding the search terms; By 7/13/2018, the Office of Personnel Management documents shall be produced, and if they are not produced the Defendants shall provide a status report with an explanation for the lack of production; Joint Status Report due by 8/17/2018. A further Status Conference is set for 9/5/2018, at 10:15 AM, in Courtroom 21, before Judge Randolph D. Moss. (Court Reporter: Jeff Hook.) (kt)

Unopposed MOTION for Extension of Time to File Status Report by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT (Attachments: # 1 Text of Proposed Order)(Sroka, Scott) (Entered: 08/17/2018)

STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 08/17/2018)

Set/Reset Deadlines: Joint Status Report due by 8/24/2018. (dot)

MINUTE ORDER: In light of Defendants' Unopposed Motion for Extension of Time to File Status Report 18, it is hereby ORDERED that the motion is GRANTED. The parties shall file their joint status report on or before August 24, 2018. Signed by Judge Randolph D. Moss on 8/17/2018. (lcrdm3, )

STATUS REPORT by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT. (Sroka, Scott) (Entered: 08/24/2018)

Supplemental STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 08/24/2018)

MINUTE ORDER: Upon consideration of the parties' joint status report 20, it is hereby ORDERED that the Department of Homeland Security ("DHS") shall file a declaration on or before August 31, 2018, explaining why it cannot review and release responsive, non-exempt records at the rate proposed by Plaintiff. Signed by Judge Randolph D. Moss on 8/27/2018. (lcrdm3, )

Set/Reset Deadlines: Department of Homeland Security ("DHS") shall file a declaration on or before 8/31/2018. (kt)

RESPONSE TO ORDER OF THE COURT re Order, Notice of Filing filed by DEPARTMENT OF HOMELAND SECURITY. (Attachments: # 1 Declaration of James V.M.L. Holzer)(Sroka, Scott) (Entered: 08/30/2018)

Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 9/5/2018. Order forthcoming. (Court Reporter Jeff Hook.) (dot)

MINUTE ORDER: In light of the status conference held on September 5, 2018, it is hereby ORDERED that the Department of Homeland Security ("DHS") shall produce records at a minimum rate of 350 pages per month. It is further ORDERED that the parties' shall file a joint status report on or before October 5, 2018, alerting the Court to DHS's progress and proposing a briefing schedule moving forward. Signed by Judge Randolph D. Moss on 9/10/2018. (lcrdm3, )

Set/Reset Deadlines: Joint Status Report due by 10/5/2018. (kt)

STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 10/05/2018)

STATUS REPORT by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT. (Sroka, Scott) (Entered: 10/05/2018)

Set/Reset Hearings: Status Conference set for 10/29/2018, at 10:15 AM, in Courtroom 21, before Judge Randolph D. Moss. (kt)

MINUTE ORDER: Upon consideration of Plaintiff's status report 23, it is hereby ORDERED that the parties shall appear for a status conference on October 29, 2018, at 10:15 a.m. in Courtroom 21. Signed by Judge Randolph D. Moss on 10/10/2018. (lcrdm3, )

Supplemental STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 10/24/2018)

Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 10/29/2018. On or before 11/1/2018, Defendants shall respond to Plaintiffs proposed narrowing of the DHS search to taskers C & D, and OMB's voluminous search to two custodians. The parties shall continue to meet and confer. Joint Status Report due by 11/16/2018. (Court Reporter: Jeff Hook.) (kt)

STATUS REPORT by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT. (Sroka, Scott) (Entered: 11/16/2018)

STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 11/16/2018)

MINUTE ORDER: Upon consideration of the parties' status reports 26, 27, it is hereby ORDERED that the parties shall meet and confer on the issues identified in Plaintiff's status report 27 . It is further ORDERED that the parties shall file a joint status report informing the Court of the outcome of these discussions on or before December 14, 2018. Signed by Judge Randolph D. Moss on 11/25/2018. (lcrdm3, )

Set/Reset Deadlines: Joint Status Report due by 12/14/2018. (kt)

Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 12/14/2018)

MINUTE ORDER: Upon consideration of the parties joint status report 28, it is hereby ORDERED that the parties shall file a further joint status report on or before January 31, 2019. Signed by Judge Randolph D. Moss on 12/16/2018. (lcrdm3, )

Set/Reset Deadlines: Joint Status Report due by 1/31/2019. (kt)

Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Iraola, David) (Entered: 01/31/2019)

MINUTE ORDER: Upon consideration of the parties' joint status report 29, it is hereby ORDERED that the parties shall file a further joint status report on or before February 15, 2019. Signed by Judge Randolph D. Moss on 2/3/2019. (lcrdm3, )

Set/Reset Deadlines: Joint Status Report due by 2/15/2019. (kt)

Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Iraola, David) (Entered: 02/15/2019)

MINUTE ORDER: Upon consideration of the parties' joint status report 30, it is hereby ORDERED that the parties shall file a further joint status report on or before March 15, 2019. It is further ORDERED that the OMB shall provide Plaintiff with information regarding the narrowed searched on or before February 22, 2019. Signed by Judge Randolph D. Moss on 2/18/2019. (lcrdm3, )

Set/Reset Deadlines: Joint Status Report due by 3/15/2019. (kt)

Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Iraola, David) (Entered: 03/15/2019)

Set/Reset Hearings

.Order

Set/Reset Hearings: Status Conference set for 4/8/2019 at 10:00 AM in Courtroom 21 before Judge Randolph D. Moss. (dot)

MINUTE ORDER: In light of the parties' joint status report, it is hereby ORDERED that the parties shall appear for a status conference on April 8, 2019 at 10:00 a.m. in Courtroom 21. Signed by Judge Randolph D. Moss on 3/20/2019. (lcrdm3, )

Joint MOTION to Continue by PROTECT DEMOCRACY PROJECT, INC. (Iraola, David) (Entered: 04/03/2019)

Notice of QC

NOTICE OF ERROR re 32 Motion to Continue; emailed to DIraola@cov.com, cc'd 7 associated attorneys -- The PDF file you docketed contained errors: 1. Do Not Refile. FYI for future filings. If you are electronically filing any document, your signature must be on the document. (ztd, )

MINUTE ORDER: Upon consideration of the joint motion to continue 32, it is hereby ORDERED that the motion is GRANTED. The status conference scheduled for April 8, 2019, is hereby VACATED. It is further ORDERED that the parties shall submit a further joint status report on or before May 6, 2019. Signed by Judge Randolph D. Moss on 4/4/2019. (lcrdm3, )

Set/Reset Deadlines

Set/Reset Deadlines: Joint Status Report due by 5/6/2018. (kt)

Order on Motion to Continue

Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Iraola, David) (Entered: 05/06/2019)

Set/Reset Deadlines

.Order

MINUTE ORDER: Upon consideration of the parties' joint status report 33, it is hereby ORDERED that OMB and DHS are no longer required to make future productions in this case. It is further ORDERED that the parties shall submit a further joint status report on or before June 21, 2019. Signed by Judge Randolph D. Moss on 5/9/2019. (lcrdm3, )

Set/Reset Deadlines: Joint Status Report due by 6/21/2019. (kt)

Status Report

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Status Report

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Notice of Substitution of Counsel

Status Report

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