Case 1:10-cv-00751-RBW Document 10 Filed 03/11/11 Page 1 of 3

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

__________________________________________
VERN McKINLEY, )
)
Plaintiff, )
v. ) Case No: 10-00751 (RBW)
)
BOARD OF GOVERNORS OF THE )
FEDERAL RESERVE SYSTEM, )
)
Defendant. )
__________________________________________)

JOINT MOTION FOR EXTENSION OF TIME AND

TO MODIFY BRIEFING SCHEDULE

Plaintiff and Defendant, by and through undersigned counsel, move to modify the

existing briefing schedule by extending the deadline for Defendant’s motion for summary

judgment, currently set for March 21, 2011, by 49 days to May 9, 2011, and to adjust other

deadlines in the schedule, and as grounds state:

1. This matter involves two FOIA requests directed to the Board of Governors of the

Federal Reserve System (the “Board”) as more fully described in the Complaint. (Compl. ¶ 5-6).

Defendant answered the Complaint on July 1, 2010.

2. Defendant has released to Plaintiff what it contends to be all non-exempt

responsive documents to the FOIA requests at issue (totaling over 2,000 pages of documents)

and, pursuant to the Court’s order dated December 3, 2010, Defendant has provided a draft

Vaughn index to Plaintiff. Plaintiff has reviewed the draft Vaughn index, and pursuant to the

referenced order, has identified for Defendant certain withholdings that Plaintiff does not intend

to challenge. However, numerous withholdings based on several exemptions remain at issue in

this action.
 Case 1:10-cv-00751-RBW Document 10 Filed 03/11/11 Page 2 of 3

3. Pursuant to the Court’s order of December 3, 2010, Defendant’s motion for

summary judgment is due March 21, 2011, and the remaining deadlines are as follows:

Plaintiff’s opposition to motion for summary judgment April 18, 2011

and cross-motion for summary judgment

Defendant’s reply in support of motion for summary May 23, 2011

judgment and opposition to Plaintiff’s cross-motion

Plaintiff’s reply in support of Plaintiff’s cross-motion June 20, 2011

Status Conference September 20, 2011

4. Due to the volume of documents at issue, as well as the number of exemptions

that remain to be briefed, Defendant requires additional time to prepare its summary judgment

motion as well as the declarations that will be filed in support of that motion.

5. Accordingly, the parties have conferred and at this time propose the following

adjustments to the briefing schedule.

Defendant’s motion for summary judgment May 9, 2011

Plaintiff’s opposition to motion for summary judgment June 20, 2011

and cross-motion for summary judgment

Defendant’s reply in support of motion for summary August 4, 2011

judgment and opposition to Plaintiff’s cross-motion

Plaintiff’s reply in support of Plaintiff’s cross-motion September 1, 2011

6. These adjustments to the schedule will still result in briefing being completed

before the existing status conference scheduled for September 20, 2011.

7. A proposed order is attached.

 Case 1:10-cv-00751-RBW Document 10
Dated: March 11, 2011
/s/
MICHAEL BEKESHA
D.C. Bar # 995749
JUDICIAL WATCH, INC.
425 Third Street, S.W., Suite 800
Washington, D.C. 20024
(202) 646-5172
Attorneys for Plaintiff
Filed 03/11/11 Page 3 of 3
Respectfully submitted,
RONALD C. MACHEN JR., D.C. Bar #447889
United States Attorney for the
District of Columbia
RUDOLPH CONTRERAS, D.C. Bar #434122
Chief, Civil Division
By: ________/s/____________________
JEREMY S. SIMON, D.C. BAR # 447956
Assistant United States Attorney
Civil Division
555 4th Street, N.W.
Washington, D.C. 20530
(202) 307-0406
Jeremy.Simon@usdoj.gov
Attorneys for Defendant