CREW v. Department of Health and Human Services:11/17/2006 - Motion to Stay

8/7/2019 CREW v. Department of Health and Human Services:11/17/2006 - Motion to Stay

1/53

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

________________________________________________

CITIZENS FOR RESPONSIBILITY AND ETHICS )

IN WASHINGTON, ))

Plaintiff, ) CV-05-1127 (CKK)

)

vs. )

)

UNITED STATES DEPARTMENT OF )

HEALTH AND HUMAN SERVICES )

)

Defendant. )

________________________________________________)

DEFENDANTS MOTION FOR A STAY OF PROCEEDINGS

Pursuant to 5 U.S.C. 552(a)(6)(C)(i) and Open Am. v. Watergate Special Prosecution

Force, 547 F.2d 605 (D.C. Cir. 1976), defendant, United States Department of Health and

Human Services, by and through its undersigned counsel, hereby move this Court for a stay of

proceedings as set forth in the accompanying Memorandum in support of this Motion.

Defendant respectfully requests that this Court order defendant to produce all documents,

besides the documents from the National Institute of Health (NIH), responsive to plaintiffs

Freedom of Information Act request on a rolling basis every six weeks, beginning January 26,

2007, and ending on August 10, 2007. For the documents from the NIH, defendant asks this

Court to order plaintiff to narrow its request to exclude all contact information or to give

defendant until January 26, 2010, to produce all such documents.

Case 1:05-cv-01127-CKK Document 25 Filed 11/17/2006 Page 1 o


2/53

2

Dated November 17, 2006 Respectively Submitted,

PETER D. KEISLER

Assistant Attorney General

JEFFREY A. TAYLORUnited States Attorney

ELIZABETH J. SHAPIRO

(D.C. Bar 418925)

Assistant Branch Director

U.S. Department of Justice

Civil Division, Federal Programs Branch

/s/Adam D Kirschner

ADAM D. KIRSCHNER

Trial AttorneyU.S. Department of Justice

Civil Division, Federal Programs Branch

Mailing Address

P.O. Box 883

Washington, D.C., 20044

Delivery Address

20 Massachusetts Ave., NW., Room 7126

Washington, D.C. 20001

Telephone: (202) 353-9265

Fax: (202) 616-8470

[email protected]

Counsel for Defendant



3/53

Case 1:05-cv-01127-CKK Document 25 Filed 11/17/2006 Page 3


4/53



5/53



6/53



7/53



8/53



9/53



10/53



11/53



12/53



13/53



14/53



15/53



16/53



17/53



18/53



19/53



20/53



21/53



22/53



23/53



24/53



25/53



26/53



27/53



28/53



29/53



30/53



31/53



32/53



33/53



34/53



35/53



36/53



37/53



38/53

Attachment 1



39/53



40/53



41/53



42/53

Attachment 2



43/53



44/53



45/53

Attachment 3



46/53



47/53



48/53



49/53

Attachment 4



50/53



51/53

Attachment 5



52/53



53/53


CREW v. Department of Health and Human Services:11/17/2006 - Motion to Stay

Documents

Transcript of CREW v. Department of Health and Human Services:11/17/2006 - Motion to Stay