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Plaintiff Hawaii Firearms Coalition and Defendant the Federal Bureau of Investigation
(“FBI”), by and through their respective undersigned counsel, hereby jointly request that the
Court vacate the current deadline for Defendant’s dispositive motion in this Freedom of
Information Act (“FOIA”) case. In support of this motion, the Parties hereby state as follows:
1. Plaintiff has requested records from the FBI regarding Hawaii’s requirement that
firearms purchasers, registrants, and owners be included in the FBI’s Rap Back database. See
2. In a Minute Order dated June 7, 2019, the Court ordered the FBI to produce and
file a Vaughn index with a supporting dispositive motion within 30 days, pursuant to Local Rule
16.3(b)(10).
3. The FBI has not yet completed its response to Plaintiff’s FOIA request and is
currently conducting a search for all potentially responsive records to Plaintiff’s request.
4. In light of the FBI’s ongoing efforts to respond to Plaintiff’s FOIA request, the
Parties have conferred and believe that a briefing schedule in this case is premature.
Case 1:19-cv-01260-RCL Document 9 Filed 06/18/19 Page 2 of 4
Accordingly, the Parties respectfully request additional time for the FBI to complete its response
to Plaintiff’s request and also to permit the Parties to confer regarding any issues associated with
the FBI’s search or withholdings prior to the filing of any dispositive motion.
5. The FBI anticipates that it will complete its search for potentially responsive
records by June 28, 2019. After the FBI completes its search, the parties will confer regarding a
production schedule for the FBI’s release of any responsive non-exempt records to Plaintiff.
In light of the above, the Parties respectfully request that the Court vacate the current
deadline for the FBI to file a Vaughn index and dispositive motion. The Parties also request that
the Court permit the Parties to file a joint status report no later than July 31, 2019, further
updating the Court regarding the FBI’s progress in responding to Plaintiff’s FOIA request. The
Parties’ status report will include a proposed briefing schedule, if one is necessary.
Respectfully submitted,
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Case 1:19-cv-01260-RCL Document 9 Filed 06/18/19 Page 3 of 4
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Case 1:19-cv-01260-RCL Document 9 Filed 06/18/19 Page 4 of 4
[PROPOSED] ORDER
In light of the Parties’ joint motion to vacate the briefing schedule, it is hereby
ORDERED that Defendant’s deadline to file a Vaughn index and supporting dispositive motion
is VACATED; and it is
ORDERED that the Parties shall file a joint status report on or before July 31, 2019,
further updating the Court regarding Defendant’s progress in responding to Plaintiff’s FOIA
_________________________ ____________________________
Date Royce C. Lamberth
United States District Judge