Case 1:17-cv-01946 Document 1 Filed 03/16/17 Page 1 of 5

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

________________________________________________

X

THE NEW YORK TIMES COMPANY

:

and CHARLIE SAVAGE,

:

Plaintiffs,

:

- against -

:

U.S. DEPARTMENT OF JUSTICE,

:

Defendant.

:

: ________________________________________________X

COMPLAINT

Plaintiffs THE NEW YORK TIMES COMPANY and CHARLIE SAVAGE, by their undersigned attorney, allege for their Complaint:
1. This is an action under the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, to obtain an order for the production of agency records from Defendant in response to a FOIA request properly made by Plaintiffs.
2. The Office of Legal Counsel (“OLC”) is a component of Defendant Department of Justice (“DOJ”) that serves several functions within DOJ.
3. One of its duties is to review all executive orders for form and legality. See 28 C.F.R. § 0.25(b).
4. Another of OLC’s duties is to review legal questions raised by other parts of the executive branch. See id. § 0.25(a).
5. The FOIA request at issue in this action seeks records related to OLC reviews of: (1) executive orders proposed by the transition team or administration of President
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Donald Trump and (2) other proposed matters raised by the Trump transition team or Trump administration.
6. DOJ has failed to respond to the request in 20 business days, as required under FOIA. See 5 U.S.C. § 552(a)(6)(A)(i).
PARTIES 7. Plaintiff The New York Times Company publishes The New York Times newspaper and www.nytimes.com. The New York Times Company is headquartered in this judicial district at 620 Eighth Avenue, in Manhattan. 8. Plaintiff Charlie Savage is a reporter for The New York Times and an employee of The New York Times Company. 9. Defendant DOJ is an agency of the federal government that has possession and control of the records that Plaintiffs seek.
JURISDICTION AND VENUE 10. This Court has subject matter jurisdiction over this action, pursuant to 28 U.S.C. § 1331 and 5 U.S.C. § 552(a)(4)(B). 11. Venue is premised on the place of business of Plaintiffs and is proper in this district under 5 U.S.C. § 552(a)(4)(B). 12. Plaintiffs have exhausted all administrative remedies available. DOJ has failed to make an initial determination with respect to Plaintiffs’ request within the timeframe set by FOIA, and Plaintiffs therefore are deemed to have exhausted all administrative remedies, pursuant to 5 U.S.C. § 552(a)(6)(C).
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FACTS 13. The records sought by the FOIA request underlying this action relate to Plaintiffs’ ongoing reporting on the operation of OLC and the early days of the Trump administration. 14. On January 28, 2017, Plaintiffs submitted a FOIA request to DOJ, seeking two categories of OLC records. 15. First, the FOIA request seeks “all e-mails, memos, and other documents related to . . . [OLC] review of proposed Trump administration executive orders for form and legality, including during the transition period.” 16. Second, the FOIA request seeks “all e-mails, memos, and other documents related to . . . [OLC] review of other proposed Trump White House matters, including during the transition period, including but not limited to whether the appointment of Jared Kushner to a White House role would violate anti-nepotism laws and whether the president’s ongoing business operations would violate the emoluments clause of the Constitution.” 17. DOJ acknowledged receipt of Plaintiffs’ FOIA request on February 27, 2017. 18. DOJ has failed to issue a response to the request within 20 business days, as required under FOIA.
COUNT I 19. Plaintiffs repeat, reallege, and reincorporate the allegations in the foregoing paragraphs as though fully set forth herein.
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20. Defendant DOJ is subject to FOIA and must therefore release in response to a FOIA request any disclosable records in its possession at the time of the request and provide a lawful reason for withholding any materials as to which it is claiming an exemption.
21. DOJ has failed to act on Plaintiffs’ request within the 20 business days required by FOIA. See 5 U.S.C. § 552(a)(6)(A)(i). Accordingly, Plaintiffs are deemed to have exhausted their administrative remedies under FOIA.
22. DOJ has no lawful basis for declining to release the records requested by Plaintiffs under FOIA.
23. Accordingly, Plaintiffs are entitled to an order compelling DOJ to produce records responsive to their FOIA request.
REQUEST FOR RELIEF WHEREFORE, Plaintiffs respectfully request that this Court:
24. Declare that the documents sought by their FOIA request, as described in the foregoing paragraphs, are public under 5 U.S.C. § 552 and must be disclosed;
25. Order DOJ to provide the requested documents to Plaintiffs within 20 business days of the Court’s order;
26. Award Plaintiffs the costs of this proceeding, including reasonable attorneys’ fees, as expressly permitted by FOIA; and
27. Grant Plaintiffs such other and further relief as this Court deems just and proper.
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Dated: New York, NY March 16, 2017

_____________/s/_________________ David E. McCraw, Esq. Legal Department The New York Times Company 620 8th Avenue, 18th Floor New York, NY 10018 phone: (212) 556-4031 fax: (212) 556-1009 e-mail: mccrad@nytimes.com Counsel for Plaintiffs

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 Case 1:17-cv-01946-PKC Document 9 Filed 04/28/17 Page 1 of 4

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ----------------------------------------------------------- x THE NEW YORK TIMES CO. & CHARLIE SAVAGE,

Plaintiffs,

17 Civ. 1946 (PKC)

v.
UNITED STATES DEPARTMENT OF JUSTICE,

ANSWER

Defendant. ----------------------------------------------------------- x

Defendant the United States Department of Justice (“DOJ”) answers the complaint as

follows:

1. Paragraph 1 of the complaint contains plaintiffs’ characterization of the nature of this

action, to which no response is required.

2. Admits the allegations in paragraph 2 of the complaint.

3. Paragraph 3 of the complaint contains plaintiffs’ characterization of DOJ regulations, to

which no response is required. To the extent a response is required, respectfully refers the Court

to those regulations for a true and complete statement of their contents.

4. Paragraph 4 of the complaint contains plaintiffs’ characterization of DOJ regulations, to

which no response is required. To the extent a response is required, respectfully refers the Court

to those regulations for a true and complete statement of their contents.

5. Paragraph 5 of the complaint contains plaintiffs’ characterization of the nature of this

action, to which no response is required.

6. Paragraph 6 of the complaint asserts conclusions of law, to which no response is

required; to the extent a response is required, denies the allegations in paragraph 6 of the

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complaint but avers that no records have been disclosed in response to the FOIA Request. 7. Denies knowledge or information sufficient to form a belief as to the truth of the
allegations in paragraph 7 of the complaint. 8. Denies knowledge or information sufficient to form a belief as to the truth of the
allegations in paragraph 8 of the complaint. 9. Admits the allegation in paragraph 9 of the complaint that DOJ is an agency of the
federal government; otherwise denies the allegations. 10. Paragraph 10 of the complaint asserts conclusions of law, to which no response is
required. 11. Paragraph 11 of the complaint asserts conclusions of law, to which no response is
required. 12. Paragraph 12 of the complaint asserts conclusions of law, to which no response is
required; to the extent a response is required, denies the allegations in paragraph 12 of the complaint.
13. Denies knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 13 of the complaint.
14. Admits the allegations in paragraph 14 of the complaint. 15. Admits the allegations in paragraph 15 of the complaint. 16. Admits the allegations in paragraph 16 of the complaint. 17. Admits the allegations in paragraph 17 of the complaint. 18. Paragraph 18 of the complaint asserts conclusions of law, to which no response is required; to the extent a response is required, denies the allegations in paragraph 18 of the complaint but avers that no records have been disclosed in response to the FOIA Request.
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19. Repeats and realleges the responses in the previous paragraphs of this answer. 20. Paragraph 20 of the complaint asserts conclusions of law, to which no response is required. 21. Paragraph 21 of the complaint asserts conclusions of law, to which no response is required. 22. Paragraph 22 of the complaint asserts conclusions of law, to which no response is required; otherwise denies the allegations. 23. Paragraph 23 of the complaint asserts conclusions of law, to which no response is required; otherwise denies the allegations. 24. Paragraphs 24–27 of the complaint constitute plaintiffs’ request for relief, to which no response is required.
Defenses 1. The government has exercised due diligence in processing plaintiff’s FOIA request and exceptional circumstances exist that necessitate additional time for the government to process the FOIA request. See 5 U.S.C. § 552(a)(6)(C). 2. Some or all of the documents requested in the FOIA request are exempt from disclosure, in whole or in part. See 5 U.S.C. § 552(b).
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WHEREFORE, defendant respectfully requests judgment dismissing the complaint and

granting such other and further relief as this Court deems just and proper, including costs and

disbursements.

Dated: New York, New York April 28, 2017

Respectfully submitted,
JOON H. KIM Acting United States Attorney for the Southern District of New York Attorney for Defendant

By: /s/ Benjamin H. Torrance REBECCA S. TINIO BENJAMIN H. TORRANCE Assistant United States Attorneys 86 Chambers Street New York, New York 10007 Telephone: 212.637.2774, .2703 Fax: 212.637.2702 E-mail: rebecca.tinio@usdoj.gov benjamin.torrance@usdoj.gov

4

 
 Case 1:17-cv-01946-PKC Document 12 Filed 09/11/17 Page 1 of 2
U.S. Department of Justice United States Attorney Southern District of New York

86 Chambers Street, 3rd floor New York, New York 10007

BY ECF The Honorable P. Kevin Castel United States District Judge United States Courthouse 500 Pearl Street New York, New York 10007

September 11, 2017

Re: New York Times Co. v. U.S. Dep’t of Justice, No. 17 Civ. 1946 (PKC)

Dear Judge Castel:

We write respectfully on behalf of the parties in the above-referenced matter in order to provide a joint status report, pursuant to the Court’s Order dated July 13, 2017 (Dkt. No. 11). As the parties anticipated in their submission dated July 12, 2017 (Dkt. No. 10), the Government completed its initial searches in response to Plaintiffs’ FOIA requests by August 31, 2017. Since that date, the parties have been conferring regarding the results of the Government’s searches and possible agreements regarding the processing of responsive documents.

In order to allow additional time for these discussions to continue, the parties jointly and respectfully request the Court’s leave to submit a further status report on October 3, 2017 (in advance of the conference scheduled for October 6, 2017, at 10:45 a.m.). In that status report, the parties anticipate outlining the progress of the case, potential agreements regarding case scheduling, or any disputes that may need to be resolved.

We thank the Court for its consideration of this matter.

Case 1:17-cv-01946-PKC Document 12 Filed 09/11/17 Page 2 of 2
Hon. P. Kevin Castel
September 11, 2017 Page 2
Respectfully, JOON H. KIM Acting United States Attorney
By: /s/ Rebecca S. Tinio REBECCA S. TINIO BENJAMIN H. TORRANCE Assistant United States Attorneys 86 Chambers Street, 3rd Floor New York, New York 10007 Tel. (212) 637-2774/2703 Fax (212) 637-2702
cc (via ECF): All counsel of record

 
 Case 1:17-cv-01946-PKC Document 14 Filed 10/02/17 Page 1 of 2
U.S. Department of Justice United States Attorney Southern District of New York

86 Chambers Street, 3rd floor New York, New York 10007

BY ECF The Honorable P. Kevin Castel United States District Judge United States Courthouse 500 Pearl Street New York, New York 10007

October 2, 2017

Re: New York Times Co. v. U.S. Dep’t of Justice, No. 17 Civ. 1946 (PKC)

Dear Judge Castel:

We write respectfully on behalf of the parties in the above-referenced matter in order to provide a joint status report, pursuant to the Court’s Order dated September 12, 2017 (Dkt. No. 13). The parties last submitted a status report on September 11, 2017 (Dkt. No. 12), stating that the Government had completed its initial searches for documents responsive to Plaintiffs’ FOIA requests, and that the parties had been conferring regarding the search results and possible agreements regarding the processing of documents. Since September 11, 2017, the parties have continued to confer, and have reached additional agreements that permitted the Government to narrow the universe of documents that must be processed. The Government estimates that there are now approximately 12,000 documents to be processed.

Per the parties’ most recent discussions, the parties have agreed that the Government will make a first release and/or response to Plaintiffs’ FOIA requests on November 10, 2017. On November 10, in addition to a potential document release, the Government will provide certain information regarding its processing of the documents, including but not limited to the number of pages reviewed, the number of documents referred out for consultation, and the number of pages currently anticipated to be withheld in whole or in part. The parties also anticipate, by November 10, being able to discuss a schedule for remaining productions and/or responses by the Government in response to Plaintiffs’ FOIA requests.

The parties therefore jointly and respectfully request: (1) the Court’s endorsement of the parties’ agreed deadline of November 10, 2017, for the Government’s first release and/or response pertaining to Plaintiff’s FOIA requests; and (2) the Court’s leave to submit a further status report on November 15, 2017. In that status report, the parties anticipate

Case 1:17-cv-01946-PKC Document 14 Filed 10/02/17 Page 2 of 2
Hon. P. Kevin Castel
October 2, 2017 Page 2
outlining the progress of the case, potential agreements regarding case scheduling, or any disputes that may need to be resolved. Furthermore, the parties note that a court conference is scheduled in this matter for October 6, 2017, at 10:45 a.m. (Dkt. No. 11). Given the parties’ agreements and the continuing progress of the case, the parties jointly and respectfully request that the October 6 conference be adjourned to a date subsequent to November 15, 2017; but the parties would be happy to appear on October 6, if the Court wishes.
We thank the Court for its consideration of this matter.
Respectfully, JOON H. KIM Acting United States Attorney
By: /s/ Rebecca S. Tinio REBECCA S. TINIO BENJAMIN H. TORRANCE Assistant United States Attorneys 86 Chambers Street, 3rd Floor New York, New York 10007 Tel. (212) 637-2774/2703 Fax (212) 637-2702
cc (via ECF): All counsel of record

 
 Case 1:17-cv-01946-PKC Document 17 Filed 11/15/17 Page 1 of 2
U.S. Department of Justice United States Attorney Southern District of New York

86 Chambers Street, 3rd floor New York, New York 10007

BY ECF The Honorable P. Kevin Castel United States District Judge United States Courthouse 500 Pearl Street New York, New York 10007

November 15, 2017

Re: New York Times Co. v. U.S. Dep’t of Justice, No. 17 Civ. 1946 (PKC)

Dear Judge Castel:

We write respectfully on behalf of the parties in the above-referenced matter in order to provide a joint status report, pursuant to the Court’s Order dated October 3, 2017 (Dkt. No. 15). The parties last submitted a status report on October 2, 2017 (Dkt. No. 14), stating that the parties had agreed that the Government would provide a response to Plaintiffs’ FOIA requests on November 10, 2017, and would also furnish additional information regarding its processing of responsive documents and a possible schedule for future FOIA responses. Since October 3, 2017, the Government did provide a FOIA response on November 10, 2017, and the parties have discussed additional information provided by the Government about the universe of responsive documents to be processed (which now comprises about fifty-four hundred documents totaling between twenty and twenty-five thousand pages).

Per these discussions, the parties have reached additional agreements and jointly and respectfully request the Court’s endorsement of the following: (1) the Government will provide additional FOIA responses on December 15, 2017, and January 15, 2018; (2) the Government will provide Plaintiffs with FOIA responses made in other litigations that are also responsive to the FOIA requests in this matter; (3) the parties will confer promptly after January 15, 2018, to discuss the status of this matter and to confer about a plan for moving forward; (4) the parties will submit an additional status report to the Court on January 19, 2018. Furthermore, the parties note that a court conference is scheduled in this matter for November 30, 2017, at 11:30 a.m. (Dkt. No. 15). Given the parties’ agreements and the continuing progress of the case, the parties jointly and respectfully request that the November 30 conference be adjourned to a date subsequent to January 19, 2018; but the parties would be happy to appear on November 30, if the Court wishes.

Case 1:17-cv-01946-PKC Document 17 Filed 11/15/17 Page 2 of 2
Hon. P. Kevin Castel
November 15, 2017 Page 2
We thank the Court for its consideration of this matter.
Respectfully, JOON H. KIM Acting United States Attorney
By: /s/ Rebecca S. Tinio REBECCA S. TINIO BENJAMIN H. TORRANCE Assistant United States Attorneys 86 Chambers Street, 3rd Floor New York, New York 10007 Tel. (212) 637-2774/2703 Fax (212) 637-2702
cc (via ECF): All counsel of record

 
 Case 1:17-cv-01946-PKC Document 19 Filed 01/19/18 Page 1 of 2
U.S. Department of Justice United States Attorney Southern District of New York

86 Chambers Street, 3rd floor New York, New York 10007

BY ECF The Honorable P. Kevin Castel United States District Judge United States Courthouse 500 Pearl Street New York, New York 10007

January 19, 2018

Re: New York Times Co. v. U.S. Dep’t of Justice, No. 17 Civ. 1946 (PKC)

Dear Judge Castel:

We write respectfully on behalf of the parties in the above-referenced matter in order to provide a joint status report, pursuant to the Court’s Order dated November 15, 2017 (Dkt. No. 18). The parties last submitted a status report on November 15, 2017 (Dkt. No. 17), stating that the parties had agreed that the Government would provide further responses to Plaintiffs’ FOIA requests on December 15, 2017, and January 15, 2018, and would also provide Plaintiffs with FOIA responses made in other litigations that are also responsive to the FOIA requests in this matter. Since November 15, 2017, the Government did provide two further responses to Plaintiffs’ requests, and also provided the relevant FOIA responses made in other litigations. Moreover, the parties have conferred further regarding a plan for moving forward.

Per these discussions, the parties have reached additional agreements and jointly and respectfully request the Court’s endorsement of the following:

(1) By March 5, 2018, the Government will provide Plaintiffs with an “index” of all documents in the Government’s production set (defined as responsive documents located via reasonable searches, subject to production and processing agreements previously reached by the parties) that have not yet been processed for release by the Government. The parties agree that the Government will endeavor to prepare and provide this index with the understanding that Plaintiffs will use it in order to make a good faith effort to limit the scope of any further document processing. The index will include the following information regarding each document:

a. Date

Case 1:17-cv-01946-PKC Document 19 Filed 01/19/18 Page 2 of 2
Hon. P. Kevin Castel January 19, 2018 Page 2
b. Type of document (e.g., email, research memorandum, opinion, etc.) c. Designation of the document as intra-agency, inter-agency, or external d. Name of the persons sending or receiving the document or otherwise
mentioned in the document (subject to appropriate withholding per FOIA exemptions, including but not limited to Exemptions 6 or 7(C)) e. Description of the topic of the document, with the Government agreeing to provide, in good faith, as much specificity as possible subject to the appropriate application of FOIA exemptions.
(2) Following the Government’s provision of the index, the parties will promptly confer regarding the possible limitation of the scope of any further document processing, and a plan for moving forward.
(3) The parties will submit an additional status report to the Court on March 20, 2018.
Furthermore, the parties note that a court conference is scheduled in this matter for January 23, 2018, at 10:30 a.m. (Dkt. No. 18). Given the parties’ agreements and the continuing progress of the case, the parties jointly and respectfully request that the January 23 conference be adjourned to a date subsequent to March 20, 2018.
We thank the Court for its consideration of this matter.
Respectfully, GEOFFREY S. BERMAN United States Attorney
By: /s/ Rebecca S. Tinio REBECCA S. TINIO BENJAMIN H. TORRANCE Assistant United States Attorneys 86 Chambers Street, 3rd Floor New York, New York 10007 Tel. (212) 637-2774/2703 Fax (212) 637-2702
cc (via ECF): All counsel of record

 
 U.S. Department of Justice
Office of Legal Counsel
Washington, D.C. 20530
December 15, 2017
Charlie Savage The New York Times savage@nytimes.com
Re: FOIA No. FYl 7-070; N.Y. Times, et al. v. DOJ, No. 17 Civ. 1946 (S.D.N.Y.)
Dear Mr. Savage:
This letter partially responds to your January 28, 2017 Freedom of Information Act ("FOIA") request to the Office of Legal Counsel ("OLC"), seeking "all e-mails, memos, and other documents related to[:] 1. Office of Legal Counsel review of proposed Trump aqministration executive orders for form and legality, including during the transition period[;] and 2. Office of Legal Counsel review of other proposed Trump White House matters, including during the transition period," through January 28, 2017. As you know, the request is also the subject of the above-captioned litigation, and the request has been narrowed in certain ways pursuant to agreement through counsel.
Since the last partial response, we have processed 213 pages of responsive records. We have eru;losed 28 pages with material redacted as exempt from disclosure pursuant to FOIA Exemption Five, 5 U.S.C. § 552(b)(5), and pursuant to FOIA Exemption Six, 5 U.S.C. § 552(b)(6). For your information, Exemption Five exempts material protected by the attorneyclient, deliberative process, and presidential communications privileges, as well as the attorney work product doctrine and other privileges. Exemption Six exempts material the disclosure of which would constitute a clearly unwarranted invasion of personal privacy. We have withheld the remaining 185 pages in full pursuant to Exemption Five, and in part pursuant to Exemption Six. We are continuing to process responsive records.
For your information, Congress excluded three discrete categories of law enforcement and national security records from the requirements of the FOIA. See 5 U.S.C. § 552(c). This response is limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.
You may contact Assistant U.S. Attorney Rebecca Tinio, at 212-637-2774, for any further assistance and to discuss any aspect of your request. Additionally, you may contact the Office of Government Information Services ("OGIS") at the National Archives and Records Administration to inquire about the FOIA mediation services they offer. The contact information for OGIS is as follows: Office of Government Information Services, National Archives and Records Administration, Room 2510, 8601 Adelphi Road, College Park, Maryland 20740-6001,

e-mail at ogis@nara.gov; telephone at 202-741-5770; toll free at 1-877-684-6448; or facsimile at 202-741-5769.
Although your request is the subject of ongoing litigation, and administrative appeals are not ordinarily acted upon in such situations, I am required by statute and regulation to inform you of your right to file an administrative appeal. You may administratively appeal by writing to the Director, Office oflnformation Policy ("OIP"), United States Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, DC 20530-0001, or you may submit an appeal through OIP's FOIAonline portal by creating an account on the following web site: https://foiaonline.regulations.gov/foia/action/public/home. Your appeal must be postmarked or electronically transmitted within 90 days of the date of my response to your request. If you submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act Appeal."
Sincerely,
/4//~
Paul P. Colborn Special Counsel Enclosures
cc: Rebecca S. Tinio Assistant United States Attorney Southern District of New York Benjamin H. Torrance Assistant United States Attorney Southern District of New York
2

•@ll!l._o_Lc_,_______________________

From: Sent: To: Subje ct: At t a ch m e nt s:

(b) (6) (OLC} Monday, December OS, 2016 8:23 PM
OLC)

(b) (5)

doc

Document ID: 0.7.13767.15847

From: Sent: To: Subject:

...
Monday, December 12, 2016 10:00 AM Hart, Rosemary (OLC} RE: Executive Orders for OLC Review (Part 1)

Thanks, Rosemary.

From: Hart, Rosemary {Ole)

Sent: Mondaw ecember 12, 201610:00 AM

To·MQJUL<

(b) (6)

Subject: FW: Executive Orders for OLC Review {Part 1}

First batch. As we discussed, all of these are a close-hold.

Thanks.

Document ID: 0.7.13767.59750

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC} Wednesday, December 14, 2016 12:02 PM
(b) (6) RE: Executive Orders for OLC Review (Part 1)

Terrific! Thanks.

From:MG)l(DII

Sent: Wednesday, December 14, 201611:47 AM

To: Hart, Rosemary {Ole)<

(b) (6)

"

Subject: RE: Executive Orders for OLC Review (Part 1}

Rosemary,l'm~ I'm turning to~ were available to review.

onthe

(b) (5)

and

(b) (5)

• rders.

ext but thought you might want to have these two for whenever you

Thank you,
WJIGJ]

Document ID: 0.7.13767.58324

Document ID: 0.7.13767.58324

Hart, Rosemary (OLC)

From: Sent: To: Subject:
Att achments:

Hart, Rosemary (OLC}

One down! But we probably need to talk about a couple items tomorrow. Thanks so much!

Document ID: 0.7.13767.58214

_ _o_L_c1_________________________

From: Sent: To: Subject:

(b) (6)

(OLC)

Wednesday, December 14, 2016 3:47 PM

Hart, Rosemary (OLC)

RE: Executive Orders for OLC Review (Part 1)

I'll be workingfrom home. Happy to talk whenever.

From: Hart, Rosemary {Ole)

Sent: Wednesday, December 14, 2016 3:46 PM

To:

OLC}<

(b) (6)

•

Subject: RE: Executive Orders for OLC Review (Part 1}

Thanks! I'll take a look. Are you here tomorrow? Or at home? (Doesn't matter, as we can email or call each other.}

From:

(b) (6)

(O l e )

Sent: Wednesday, December 14, 2016 3:41 PM

To: Hart, Rosemary (OLC) <

(b) (6 )

•

Subject: RE: Executive Orders for OLC Review (Part 1}

Here are two. I didn't have any comments on th,,MmJR I'm still working on the ltiJI&J)one.
I'm happy to discuss!

From : Hart, Rosemary {OLC)

Se ~ To: ~

20163:53 PM

OLC} ·

(b )(6 )

•

Subject: FW: Executive Orders for OLC Review {Part 1)

• Your 4 EOs are attached.

Rosemary

Document ID: 0.7.13767.49267

Document ID: 0.7.13767.49267

_ _o_L_c_)__________________________

From: Sent: To: Subject: Attachments:

(b) (6)

(OLC)

Thursday, December 15, 2016 7:21 AM

Hart, Rosemary {O le)

RE:

(b) (5)

(b) (5)

11 (12-11-2016) +
12-11-2016) +• .docx

I agree with both of your comments (
(b) (5)
changes and deleted the comments.

(b) (5) , and made corresponding

From: Hart, Rosemary (OLC)

S e n ~er 14, 2016 8:19 PM

To: ~

(O LC)

Subject:

(b)(5)

+.
( 12-11-2016}

Thanks for taking the first shot at this! Afew nits and a couple of questions, in the attached.

RH

Document ID: 0.7.13767.48982

Hart, Rosemary (OLC)

From: Sent: To: Subject:
Att achments:

Hart, Rosemary {Ole)
i l l+rh.docx

(b) (5)

12-11-2016} + (12-11-2016) +

wmm) This looks great. I had a couple of tweaks, and also noted an issue that could benefit from follow-up
with Dan.

inlU>ll!JI I gave this to Paul to look at, given the language

He wants to meet on this and I told him we'd

do that after you got in.

Thanks! Rosemary

Document ID: 0.7.13767.58015

Hart, Rosemary (OLC)

From: Sent: To: Subject: At t a ch m e nt s:

Hart, Rosemary {Ole) Thursday, December 15, 2016 1:11 PM
(b) (6) (Ole)

2016).docx; ATT00002.htm;

16).docx; ATT00003.htm;

(b) (5)

-

12-12-2016).docx; ATT00004.htm; ATTOOOOS.htm

[l;JIOJ]: Please review the three attached orders. It would be great if you could have redlines back to me by
next Tuesday. I'll stop by this afternoon to have a preliminary discussion about them.
Thanks, Rosemary

Document ID: 0.7.13767.37767

Document ID: 0.7.13767.37767-000001

Document ID: 0.7.13767.37767-000002

Document ID: 0.7.13767.37767-000003

Document ID: 0.7.13767.37767-000004

Hart, Rosemary (OLC)

From: Sent: To: Subject: At t a ch m e nt s:

Hart, Rosemary (OLC}

Thursday, December 1 5, 201 6 1:12 PM

(b) (6)

(OLC}

New EOs
(b) (5)

(12-13-16).docx; ATTOOOOS.htm

illi Would you please review the attached proposed EO?
Thanks! Rosemary

Document ID: 0.7.13767.48944

Document ID: 0.7.13767.48944-000001

- m x m_ _o_LC•) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

From:
Sent: To: Subject:

(b) (6)

(OLC)

Thursday, December 15, 2016 1:43 PM

Hart, Rosemary {Ole)
RE: IO)JtiJJ

Yes-they're fine.
From: Hart, Rosemary (OLC) Sent: Thursda Decemb-er 15, 2016 1:37 PM
(OLC}

On QNI.did you

(b) (5)
(b) (5)

From :

(b) (6)

{OLC)

Sent: Thursday, December 15, 20161:35 PM

To: Hart, Rosemary (OLC) <

(b) (6)

•

Subject: Re: a B

One more question-(b) (5) ?
(b) (6)
Attorney-Adviser
Office of Legal Counsel (b) (6)

(b) (5)

On Dec 15, 2016, at 1:32 PM, Hart, Rosemary (OLC) <~

Right-

(b) (5)
(b) (5)

wrote:

From : l l l l l l l l l l l l l f f(OLC}

Sent: ~

01610:48AM

To: Hart, Rosemary (OLC) <

(b) (6 )

•

Subject: USI

Here' s the last one.

(b) (5)

--------(-b--)-(-5--)---·--------·- .

Document ID: 0.7.1 3767.48873

« FIie: >>
llllllllllllffi
~
Office of Legal Counsel
IIIIIDDJIIII

(b) (5)

12-11-2016)+. Clocx

Document ID: 0.7.13767.48873

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Thursday, December 1 5, 201 6 1:53 PM

(b) (6)

,OLC}

RE: MJ&JJ

Only if it would be reasonably quick. I'll ask Steve next time we talk.

From:

(b) (6)

(Ol e)

Sent: Thursday, December 15, 20161:44 PM

To: Hart, Rosemary {Ole) <

(b )(6 )

•

Subje ct: Re: Eil!JI

(b) (5)
(b) (6)
Attorney-Adviser Office oflegal Counsel
(b) (6)

is it something I should spend time running to ground if I'm not sure?

On Dec 15, 2016, at 1:37 PM, Hart, Rosemary (OLC) ~ wrote:

Document ID: 0.7.13767.48855

Document ID: 0.7.13767.48855

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}
· -Thursday, December 15, 2016 1:54 PM
RE: EOs for OLC

Thanks! I'll check with Dan and Paul on schedules.

From: (b) (6)

Sent: Thursday, December 15, 20161:52 PM

To: Hart, Rosemary (Ole) <

(b) (6)

"

Subject: RE: EOs for OlC

Yes, happy to review. I've also had a chance to look at your edits tothe WJI&J]order and am ready to talk with Dan and Paul whenever it's convenient for you.

From: Hart, Rosemary (OLC)
Sent: Thursday, December 15, 2016 1:15 PM
To· H-AJffiH <==== (b) = (6)==="
Subject: FW: EOs for OlC

tlDm: I would appreciate it if you could review the first of these -the one

(b) (5)

I've

assigned the nextthree tolG)Jljl and the

ollllli

Thanks!

Rosemary

Document ID: 0.7.13767.57951

Document ID: 0.7.13767.57951

- t i J I U J - -(O_L.c)_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

From: Sent: To: Subject: Attachments:

(b) (6)

(OLC)

Thursday, December 1 5, 201 6 4 :55 PM

Hart, Rosemary (OLC)

RE:

(12-11-2016)

These look good. I deleted the internal comments.

From: Hart, Rosemary (OLC)

Sent: Thursday, December 15, 2016 4 :38 PM

To:

OLC

Subject:

-- another redline

• Sorry for the delay. I got interrupted several times.

When talking with Dan about a couple of other things,

I will be tied up for another hour, so no rush to get this back to me. We can send it tomorrow along with the others.

Thanks so much -

(b ) (5)

RH

Document ID: 0.7.13767.48733

(b) (6)

(OLC)

From: Sent: To: Subject: Attachments

(b) (6)

(OLC)

Thursday, December 15, 2016 4:57 PM

Hart, Rosemary (OLC)

(b) (5)

(b) (5)

(12-13-16)

(b) (6) .docx

Here are my comments on this one .

(b) (5)

(b) (6)
Attorney-Adviser Office of Legal Counsel
(b) (6)


 


Document ID: 0.7.13767.48727

IIDI
From: Sent: To: Subje ct: Att achments:

MW•&M
Thursday, December 1 5, 201 6 4 :58 PM

Hart, Rosemary (OLC}

RE: Executive Orders for OLC Review (Part 1)

(b) (5)

12-11-2016) + 11,docx

Rosemary: Here's the

(b) (5)

order. I have a number of quest ions highlighted,

some of which I could probably nail down with just a little more research (or a conversation with you or

Dan). I can focus on those tomorrow morning but wanted to give you this draft in case you're planning to

review tonight.

(b) (5)

From: Hart, Rosemary (OLC) Sent: Monda , December 12, 201610:00 AM

Document ID: 0.7.13767.57730

Document ID: 0.7.13767.57730

-mjm-.(o_L_c1______________________

From: Sent: To: Cc: Subject:

(b) (6)

OLC)

Thursday, December 15, 2016 7:31 PM

Hart, Rosemary (OLC)

Koffsky, Daniel L (OLC)
Re: - -(003) + rh 230 pm

(b) (5)

12-11-2016)

(b) (5)

(b) (6) Attorney-Adviser Office of Legal Counsel
(b) (6)
On Dec 15, 2016, at 6:25 PM, Hart, Rosemary (O LC) <
(b) (5)

(b) (6)

• wrote:

From: Koffsky, Daniel L (OLC)

Sent: Thursday, December 15, 2015 6:16 PM

To: Hart, Rosemary (OLC) <!

(b) (6)

•

Cc:

OLC} <

(b) (6)

Subject: RE:

(b) (5)

(003) + rh 230 pm

From a different perspective:
MG>IQW

From: Koffsky, Daniel L (Ole)

Sent: Thursday, December 15, 2016 6:12 PM

To:~

Cc: ~

OLC)

Subject: RE:

(b) (5)

+ rh 230 pm

Thanks.

•
(b) (5)

(12-11-2016}f l i ( 1 2 - l l -2015 )+ i l l l (003)

Document ID: 0.7.13767.48160

(b) (5)

From: Hart, Rosemary (Ole)

Sent: Thursday, Decemb.er 15, 2016 5:52 PM

To: Koffsky, Daniel L (OLC)

Cc:

(OLC)

S ubj e c t :

230 pm

12-11- 2016). (003) + rh

Dan: Here is what. nd I have come up with. Please let us know if you have anyth ing to add or change.

Rosemary

Document ID: 0.7.13767.48160

U.S. Department of Justice
Office of Legal Counsel
Washington, D. C. 20530
November 30, 2017
Ian Bassin Executive Director The Protect Democracy Project FO IA. protectdemocracy@gmail.com
Re: FOIA No. FY17-135; Protect Democracy Project v. DOJ, No. 1:l7-cv-815 (D.D.C.)
Dear Mr. Bassin:
This letter partially responds to your February 15, 2017 Freedom oflnformation Act ("FOIA") request in which you sought five categories of "records created between January 20, 2017 and the present" regarding Executive Order 13769. As you know, the request is also the subject of the above-captioned litigation.
Since the last partial response, we have processed 285 pages ofresponsive records. We have enclosed 123 pages of, with material redacted as exempt from disclosure pursuant to FOIA Exemption Five, 5 U.S.C. § 552(b)(5), and pursuant to FOIA Exemption Six, 5 U.S.C. § 552(b)(6). For your information, Exemption Five exempts material protected by the attorneyclient, deliberative process, and presidential communications privileges, as well as the attorney work product doctrine and other privileges. Exemption Six exempts material the disclosure of which would constitute a clearly unwarranted invasion of personal privacy. We have withheld the remaining 162 pages in full pursuant to Exemption Five, and in part pursuant to Exemption Six. We are continuing to process responsive records.
For your information, Congress excluded three discrete categories of law enforcement and national security records from the requirements of the FOIA. See 5 U.S.C. § 552(c). This response is limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.
You may contact Matthew Berns of the Civil Division, Federal Programs Branch, at 202-616-8016, for any further assistance and to discuss any aspect of your requests. Additionally, you may contact the Office of Government Information Services ("OGIS") at the National Archives and Records Administration to inquire about the FOIA mediation services they offer. The contact information for OGIS is as follows: Office of Government Information Services, National Archives and Records Administration, Room 2510, 8601 Adelphi Road, College Park, Maryland 20740-6001, e-mail at ogis@nara.gov; telephone at 202-741-5770; toll free at 1-877-684-6448; or facsimile at 202-741-5769.

Although your requests are the subject of ongoing litigation, and administrative appeals are not ordinarily acted upon in such situations, I am required by statute and regulation to inform you of your right to file an administrative appeal. You may administratively appeal by writing to the Director, Office oflnformation Policy ("OIP"), United States Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, DC 20530-0001, or you may submit an appeal through OIP's FOIAonline portal by creating an account on the following web site: https://foiaonline.regulations.gov/foia/action/public/home. Your appeal must be postmarked or electronically transmitted within 90 days of the date of my response to your request. If you submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom oflnformation Act Appeal."
Sincerely,
~J~
_Jr,:- Paul P. Colborn
Special Counsel Enclosures cc: Matthew Berns, Trial Attorney
Civil Division, Federal Programs Branch
2

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

-,m-,-,-m•....- F "d J

13 2017 1:07 PM

(b) (6)

,OLC};

FW:

(b) (5)

Document ID: 0.7.12561.54194

Document ID: 0.7.12561.54194

Document ID: 0.7.12561.54194

-l;Jll!J-_o_Lc).___________________

From: Sent: To: Subje ct: Att achments:

(b) (6) {OLC)

Friday, January 13, 2017 4:54 PM

(b) (6)

(OLC)

RE:

(b) (5)

(b) (5)

(l l f l .docx

(1-13-2017)--Clean

Here it is. Good luckl

Fr om:

(b) (6)

OLC)

Sen- : Frida Janua 13, 201712:31 PM

To:

• •

OLC) <

(b)(6)

•

Subject: FW:

(b) (5 )

I'm sorry to drag you in on this. The hope ls to get it to Rosemary today. can we discuss how to divide up?

From : Hart, Rosemary {OLC}

Se n ~ 10:47AM

To: IIIIIIIIIIIIIWl(OLC)<

(b)(6)

-

Cc:

Subject: FW

11 D N • let me know if you need help on this. (Should we pull -

RH

in on this?)

Document ID: 0.7.12561.23238

(b) (6)

OLC)

From: Sent: To: Cc: Subject: Attachments:

(b) (6)

{OLC)

Friday, January 13, 2017 6:21 PM

Hart, Rosemary (OLC)
(b) (6) {OLC)

(b ) ( 5 )

(b)(5)

FYI, for jumping in on this.

(b) (5)

1-13-2017)-Thanks to -

Document ID: 0.7.12561.6924

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC} Saturday, January 14, 20171:36 PM
(OLC} - Update!!

Thanks! Will be able to look at it fairly soon.

From:

(b)(6 )

(OLC)

Sent: Saturday, January 14, 20171:35 PM

To: Hart, Rosemary (OLC) <

Subject: RE:

Here are comments on the revised version.

From: Hart, Rosemary (OLC)

Sent: Saturday, January 14, 201712:16 PM

To:

OLC}<

(b ) ( 6 )

•

Subject: RE:

- Update!!

Excellent. Thanks.

From:

(b) (6)

{OLC)

Sent: Saturday, January 14, 201712:02 PM

To: Hart, Rosemary (OLC) <

Subject: Re:

Yes, I can do this shortly.

(b) (6)

Attorney-Adviser

~

unsel

IIIIIIIIIVmUIII

On Jan 14, 2017, at 10:14 A.i\.1, Hart, Rosemary (OLC) <

(b) (6)

. wrote:

• See new redline from Steve. Please use this one -sorry. I hope it won't take too long to transfer your comments - and maybe some have been addressed in the attached version. Would you be able to turn this around today?

Thanks, Rosemary

Document ID: 0.7.12561.6887

Document ID: 0.7.12561 .6887

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Saturday, January 14, 2017 4:20 PM

(b)(6)

,OLC}

RE:

(b) (5)

- Update! !

Thanks for checking. I had to do a conference call on~ now inputting my edits. I'm about halfway through. _

have turned back to this and am

From: ~ Sent: S~
To: Hart, Rosemary (Ole) < Subject: Re:

OLC) 4:18PM

I'm a:>suming you got tied up on other matters, but I w anted to be sure I hadn't missed this.
(b) (6)

On Jan 14, 2017, at 2:46 PM, Hart, Rosemary (OLC) ~ wrote: Am preparing a redline back, which I should be able to send in the next 15-20 minutes.

Document ID: 0.7.12561.6867

Document ID: 0.7.12561 .6867

Hart, Rosemary (OLC)

From: Sent: To: Subject:
Attachments:

Hart, Rosemary (OLC}

Saturday, January 14, 2017 5:20 PM

(b) (6)

,OLC}

Copy of I 2017)-t-- 002) + rh.docx

(b) (5)

1-141-14-

Here it is, just as you are getting ready for dinner and

(b)(6)

SORRY! Everything is going more slowly than I' d like, and I kept getting interrupted with
m)J&JJ

(b) (5)

Document ID: 0.7.12561.6847

(b) (6 )

(OLC)

From:

(b) (6)

OLC)

Sent:

Saturday, January 14, 2017 5 :23 PM

To:

Hart, Rosemary (OLC)

Subject:

Re: Copy of

1-

14-2017)

Don't worry! I know you are slammed!
(b) (6) Attorney-Adviser Office of Legal Counsel
(b) (6)

Document ID: 0.7.12561.6830

--mjm--.0.L.c1______________________

From:

(b) (6)

(OLC)

Sent:

Saturday, January 14, 2017 5:37 PM

To:

Hart, Rosemary (OLC)

Subject:

RE: Copy of I

(1-

14-2017)

I'm sorry for not having this straight, but

(b) (5)

?

Document ID: 0.7.12561.6829

-mlm--.(O•L•C•)______________________

From: Sent: To: Subject:
Attachments:

(b) (6)

(OLC)

Saturday, January 14, 2017 6:01 PM

Hart, Rosemary {O le)

RE: Copy of 14-2017)-t
Copy of

(b) (5)

2017)+. (002} + rh+. docx

(1(1-14-

Here ls a revision. I've deleted the internal comments that required no follow up, and have otherwise highlighted in yellow my responses/edits. I'm happy to discuss.
(b) (5)

Document ID: 0.7.12561.6835

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Saturday, January 14, 2017 6:05 PM

(b) (6)

,OLC}

RE: Copy of
14-2017)

Ok. I had j ust started- caught me in time!

From:

(b) (6)

OLC)

Sent; Saturday, January 14, 2017 6:04 PM

To: Hart, Rosemary (OLC) <

Subject: Re: Copy of

+ rh

Ok--don't look at the doc I j ust sent. I will fix this and resend.
(b) (6) Attorney-Adviser Office of Legal Counsel
(b) (6)

On Jan 14, 2017, at 6:02 PM, Hart, Rosemary {OLC) ~

(b) (5)

I

1-
(1-14-2017)+1- 002) wrote:

Document ID: 0.7.12561.6809

- a · a - ~(0-LC~)_ _ _ _ _ _ _ _ _ _ _ _ _ __

From: Sent: To: Subject:
Attachments:

(b) (6)

{OLC)

Saturday, January 14, 2017 6:12 PM

Hart, Rosemary (OLC)

RE: Copy of
14-2017) '

Copy of
2017}+. (002) + rh+illdocx

(b) (5)

(1(1-14-

With that change made. Sorry about that!

Document ID: 0.7.12561.6813

Document ID: 0.7.12561 .6813

Hart, Rosemary (OLC)

From:

Hart, Rosemary (OLC}

Sent:

Saturday, January 14, 2017 6:17 PM

To:

(b) (6)

(OLC}

Subject:

(1-

Got it. Thanks for looking at this so quickly!

Document ID: 0.7.12561.6810

Document ID: 0.7.12561 .6810

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Saturday, January 14, 2017 6:39 PM

(b) (6)

,Ole)

RE: questi on............ .

Got it. Thanks!

From:

(b) (6)

(OLC)

Sent: Saturday, January 14, 2017 6:36 PM

To: Hart, Rosemary {OLC) <

(b) (6)

>

Subject: RE: questi on... ......... .

From: Hart, Rosemary {OLC)

Sent: Sat urday, January 14, 2017 6:29 PM

To:

OLC}<

(b)(6)

•

Subject: question.... ..... ....

Question: Not sur e I underst and this addition:

I am here at(tiJIG)]ifa call is easier.
duplicate
Document ID: 0.7.12561.6790

Document ID: 0.7.12561 .6790

(b) (6)
From: Sent: To: Subje ct: Att achments:

O LC)

(b) (6)

{OLC)

Monday, January 16, 2017 1:49 PM
(b) (6) (Ole)

RE: Immigration EO

(b) (5)

{1.16.16)+. docx

Sorry for all the confusion. Rosemary said she was

Near Final
(b) (6)

Fr o m :

(b) (6 ) (OLC)

Se n ~171:42PM

To: ~

(OLC} ,

(b)(6)

.

Subject: Re: Immigration EO

Not right now, no.
(b) (6) Attorney-Adviser Office of Legal Counsel
1• : D I 1mment of Justice

On Jan 16, 2017, at 1:39 PM,

(b) (6)

Are you working on something else now?

(OLC)

From:

(b) (6)

{OLC)

Sent: Monday, January 16, 20171:40 PM

To:

OLC) <

(b ) (6)

•

Subject: Re: Immigration EO

Ok. Let me know if you need help!
(b) (6 ) Attorney-Adviser Office of Legal Counsel Department of Justice

Document ID: 0.7.12561.28075

wrote:

(b) (6)

On Jan 16, 2017, at 1:3S PM,

(b) (6)

Nope; if you' re not, don't worry about it.

{OLC) <

(b) (6)

· wrote:

From:

(b) (6)

Ole)

Sent: Monday, January 16, 20171:38 PM

To:

OLC) <

(b) (6)

·

Subject: Re: Immigration EO

Hey, I'm not sure if I missed an email, but this is the fi rst I've heard about it. Should I be wo rking on it?
(b )(6)
Attorney-Adviser Office of Legal Counsel Department of Justice
(b) (6)

{Ole}

(b) (6)

and am back to focusing on this. Are you

working on it? If so, should we chat about whe re th ings stand?
l'matllU,ilfF

Document ID: 0.7.12561.28075

-IDIE--_o_Lc.1____________________

From: Sent: To: Subject:

(b) (6)

{OLC)

Monday, January 16, 2017 2:08 PM
(b) (6) Ole)

RE: Immigration EO

Yeah. can you also

From:

(b) (6)

Ole)

Sent: Monday, January 16, 2017 2:05 PM

To:

Ol e} ,.

Subject: RE: Immigration EO

(b) (5)

(b )(6 )

•

From:

(b) (6)

OLC)

Sent: Monday, January 16, 20171:51 PM

To:

(Ol C)<

(b) (6)

Subject: RE: Immigrati on EO

· (b) (5)

Document ID: 0.7.12561.27949

Document ID: 0.7.12561 .27949

•@Jl!J._o_Lc_)______________________

From: Sent: To: Subject:

(b) (6) OLC)
Monday, January 16, 2017 2:41 PM (OLC}

Sounds good.

From :

(b )(6)

(Ole)

Sent: Monday, January 16, 2017 2:39 PM

Give me 5 minutes. I'm going to send you the doc back with a draft comment.
From: (b) (6) {Ole) Sent: Monday, January 16, 2017 2:39 PM
Ole} <
Exactly.

(b) (5)

(b) (6)

(Ole)

Oddly, though,
1111
This raises the question-

(b) (5)

(b) (5)

·

From: (b) (6) (OLC) Sent: Monday, January 16, 2017 2:26 PM
OLC <

Document ID: 0.7.12561.27952

(b) (5)
From: (b) (6)
Sent: Monda
To:
Subject:
Document ID: 0.7.12561.27952

-,OJQ!lalll(.o_L_c1..._____________________

From: Sent: To: Cc: Subject: Attachments:

(b) (6)

(OLC)

Monday, January 16, 2017 3:56 PM

Hart, Rosemary (Ole}

(b) (6)

(OLC)

(b) (5)

(b) (5)

(1.16.16)f i l docx

Near Final

Rosemary-
In
the course of our discussion, attached comments.
- --again as reflected in the draft.

Document ID: 0.7.12561.27703

(b) (6) (OLC}

From: Sent: To: Subject:

(b) (6) {OLC)

Monday, January 16, 2017 3:58 PM

(b) (6)

{OLC)

Read:

(b) (5)

Your message
To: ~
Sub~ Sent: Monday, January 16, 2017 8:55:47 PM (UTCt00:00) Monrovi a, Reykj avi k
was read on Monday, January 16, 2017 8:57:07 PM (UTC+-00:00) Monrovia, Reykj avi k.

Document ID: 0.7.12561 .27690

.,.l!J._o_Lc_)_____________________

From: Sent: To: Subject:

(b) (6)

(OLC)

Monday, January 16, 2017 4:10 PM

(b) (6)

{Ole}

RE:

(b) (5)

(b) (5)

From:

(b) (6)

(Ole)

Sent: Monday, January 16, 2017 4:08 PM

(b) (6)
Attorney-Adviser Office of Legal Counsel

(b) (5)

On Jan 16, 2017, at4:04 PM, Yeah.

(b) (6)

(Ole)<

(b) (6)

(b) (5)

• wrote:

From:

(b) (6)

Ole)

Sent: Monday, January 16, 2017 3:59 PM

To:

OLC <

Subject: Re:

(b) (5)

(b) (6)
Attorney-Adviser Office of Legal Counsel
(b) (6)
On Jan 16, 2017, at 3:57 PM,

(b) (6)

(Ole)<;
(b ) (5 )

(b) (6)

>wrote:

Document ID: 0.7.12561.27679

(b) (5)
(b) (6)

Got it; thanks!

From:

(b) (6)

{OLC)

Sent: Monday, January 15, 2017 3:47 PM

To: I

OLC <

Subject: RE:

consultation"

inEJE>I I accidentally left a pasted

after the text, please ignore it.

(b) (6)

(b) (6)

•

This looks great (

(b) (5)

• I

made a few edits in yellow. Let me know if they make sense.

(b) (6)

(b ) (6)

•

Feel free to do more:

Document ID: 0.7.12561.27679

From: (b) (6) (OlC)

Sent: Monday, January 16, 2017 3:19 PM

To:

OLC <

Sub·

(b) (6) Document ID: 0.7.12561.27679

I think that's all fair, and I'll made edits accordingly.

From:

(b) (6 )

Ole)

To:· · · Sent: Monday, January 16, 2017 3:10 PM

Subject: RE:

OlC

I have made some edits in yellow bellow that are

totally up to you whether or not to include, as they do make it longer. I didn't

touch

(b) (5)

Thanks! Take a look? Document ID: 0.7.12561.27679

From:

(b) (6)

Ole}

Sent: Monday, January 16, 2017 2:47 PM

OLC

This may be relevant-

(b) (5)

Document ID: 0.7.12561 .27679

Document ID: 0.7.12561 .27679

Document ID: 0.7.12561 .27679

•@•@• .o.Lc).________________________

From: Sent: To: Subject:

(b) (6)

(OLC)

Monday, January 16, 2017 4:11 PM

(b) (6)

(OLC}

RE:

(b) (5)

Definitely.

From:

(b) (6)

(Ole)

Se nt: Monday, January 16, 2017 4:07 PM

To:

(OlC)<

(b)(6)

Subject: Re:

(b) (5)

Yes.

(b) (5)

(b) (6)
Attorney-Adviser ~ Counsel
IIIIIIIVWHIII

Document ID: 0.7.12561.27683

Document ID: 0.7.12561 .27683

Document ID: 0.7.12561 .27683

Document ID: 0.7.12561 .27683

Document ID: 0.7.12561 .27683

Document ID: 0.7.12561 .27683

Document ID: 0.7.12561 .27683

Hart, Rosemary (OLC)

From: Sent: To: Subject:
Attachments:

Hart, Rosemary (OLC}

Monday, January 16, 2017 6:43 PM

(b) (6)

(OLC}

(1.16.16)+l l ldocx

(b) (5)

Near Final Near Final

Thanks for continuing to work on this. I have added some internal comments and questions. See attached. And call if it is easier to d iscuss.

Document ID: 0.7.12561.27621

-w·w-.o.Lc.)____________________

From: Sent: To: Subject:
Att achments:

(b) (6)

(O LC)

Monday, January 16, 2017 7:00 PM

Hart, Rosemary {O LC)

RE: (1.16.16)+

Near Final

I'll call you in 5 minutes; I need to relocate.

Document ID: 0.7.12561.27622

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Monday, January 16, 2017 7:03 PM

(b) (6)

(OLC}

Your messag.e
Near Fi nal (1.16.16)+. anada) was read on Monday, January 16, 2017 7:03:25 PM (UTC-05:00) Eastern Time (US & Canada).

- Near

Document ID: 0.7.12561.27612

(b) (6)

(OLC)

Fro m: Sent: To : Subject:

(b) (6)

OLC)

Monday, January 16, 2017 7:18 PM

Hart, Rosemary (OLC)

RE:

Attachments:

-Near Final

Document ID: 0.7.12561.27614

- @ • @ - - .0.L.c1_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

From: Sent: To: Subject:
Att achments:

(b) (6)

O LC)

Monday, January 16, 2017 7:29 PM

Hart, Rosemary {O LC)

RE: (1.16,16) I I

Near Final

Here, with hopefully the things we've discussed addressed for tonight's purposes.

Document ID: 0.7.12561.27611

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Monday, January 16, 2017 7:29 PM

(b) (6)

(OLC}

Thanks. Will read now.

-Near Final

Document ID: 0.7.12561.27602

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Monday, January 16, 2017 7:45 PM

(b) (6)

OLC}

RE:

(b) (5)

(1.16.16)-+III

This is good. I can clean up and send. Thanks !

-Near Final

Document ID: 0.7.12561.27601

Hart, Rosemary (OLC)

From: Sent: To: Subject: At t a c h m e nt s:
Importance :

Hart, Rosemary (OLC}

Tuesday, January 17, 2017 10:21 AM

(b) (6)

(OLC}; (b) (6)

(b) (5 ) -- PLEASE READ

(b)(5)
(1.16.16)+ OLC again (116 2017).docx

High

{OLC)

(b) (5)

Near Final

Document ID: 0.7.12561.27346

am•w•(.O_Lc_)___________________

From: Sent: To: Subject:

(b) (6) {OLC)

Tuesday, January 17, 201712:23 PM

(b) (6)

(OLC)

RE: llllllll6JIIIII PLEASE READ

Yeah, that I don't know. It's a good question.
(b) (6)

(b) (5)

(b) (6)

Attorney-Adviser

~

ounsel

IIIIIIIIVWUIIII

On Jan 17, 2017, at 12:16 PM

(b) (5)

(b) (6) Ole) <;

(b) (6)

· wrote:

From:

(b) (6)

(OLC)

Sen ~ry 17, 201712:14 PM

To:-.w.&lllalll(Ole) <

(b) (6)

Subject: Re:

(b) (5) -- PLEASE READ

(b) (5)

Am

jumping on a call on another matter, but I can call you when I'm done.

(b) (6)
Attorney-Adviser Office of Legal Counsel
(b) (6)

Document ID: 0.7.12561.27294

On Jan 17, 2D17, at 12:04 PM,

(b) (6) OLC) <.

(b) (6)

Hey, I just tried calling you.

(b)(5)

From:

(b) (6)

(O LC)

Sent: Tuesday, January 17, 201711:54AM

To: Hart, Rosemary {OLC)

(b) (6 )

.,

Cc: ~

(b) (6)

Subject: Re:- -- PLEASE READ

> wrote:

(b) (6 ) Attorney-Adviser Office of Legal Counsel
(b )(6)
On Jan 17, 2017, at 11:35 AM, Hart, Rosemary {OLC) <

(b) (6 )

>wrote:

OK. Thanks. Dan should be back soon, and I can ask him for his ideas
on this.

From: (b) (6) OLC)

Sent: Tuesday, January 17, 201711:22 AM

To: Hart, Rosemary (OLC) <

(b) (6)

- (b)(6)

fiJmJIOLC} •

(b) (6)

>

Subject: RE: (b) (5) - PLEASE READ

From: (b) (6) (OLC)
Sent: Tu esdav. Januarv 17. 2017 10:47 AM
Document ID: 0.7.12561.27294

_ _ ,.,...,,. . - - - - - , . , · - · · - - · 1 - · , - - - · - - - .. . .. . . .. .
To: Hart, Rose
IBlml(OLC <
Subject: RE:

>·, (b) (6)

That could work, Ithink.

(b) (5)

Document ID: 0.7.12561.27294

>; l t i ) I m l

From: (b) (6) OLC)
Sent: Tuesday, January 17, 201710:43 AM To: Hart, Rosemary (Ole)< W>J® (OLC) Subject: RE:
l see. OK.
I'll see what I can find.

; I (b)(6)

From: Hart, Rosemary (OLC)

Sent: Tuesday, January 17, 201710:37 AM

To:

(b) (6)

OLC}

E E J I - (b)(6) (OLC) <
Subject: RE:

(b) (6) PLEASE READ

(b ) (5)

;IQJM
•

From: (b) (6) OLC)
Sent: Tuesday, January 17, 201710:28 AM
To: Hart, Rosema OLC <
ru)lmloLC} <
Subject: RE:

(b ) (6)

Document ID: 0.7.12561.27294

Document ID: 0.7.12561.27294

_ _(o_Lc_)_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

From: Sent: To: Subject:

(b) (6)

(OLC)

Tuesday, January 17, 2017 12:26 PM

OLC)

I believe tE)Uwrote the comment, so I'm sure he would know.

From :

(b) (6)

(OLC)

Sen ~17 l2:25 PM

To: 1111111111111W.OLC} <

(b) (6)

•

Subject: RE: (b)(5) - PLEASE READ

From somethingl J lsent me earlier:
- If you need a sample comment, here's one ofQiJMs that might be helpf ul:

Fr o m :

(b) (6)

(OLC)

Document ID: 0.7.12561.27276

sent: Tuesoa , January 17, 201712:24 PM

To

(Ole}<

Subject: Re:

-- PLEASE READ

Is there a cite for
(b)(6)
Attorney- Advise r Office of Legal Counsel
(b) (6)

(b) (5)

I should look at?

On Jan 17, 2017, at 12:22 PM, (b) (6) (Ole} <

(b)(6 )

But, yeah, feel free to call me when you are free at (b) (6)

• wrote:

Document ID: 0.7.12561.27276

Document ID: 0.7.12561 .27276

Document ID: 0.7.12561 .27276

Document ID: 0.7.12561 .27276

Document ID: 0.7.12561 .27276

lltiJJUJ._oL~c)_ _ _ _ _ _ _ _ _ _ _ _ _ _ __

From: Sent: To: Subject:

(b) (6) (OLC)

Tuesday, January 17, 201712:53 PM

(b)(6)

,OLC)

RE: (b) (5) - PLEASE READ

Let's talk. I chatted withWJIUJ].

withltDIGJlin But, I think might be easier to talk about this on the phone, or for you to discuss

person and

explain the actual issue we are dealing with. There does seem something different here in that the

I

(b) (5)

(b) (6)

Ole)

I would j ust ask him the question generally-

llllllllfflTffl
~
Office of LI ii Counsel
MQJ1m
On Jan 17, 2017, at 12:32 PM,

(b) (6) (OLC) <

(b) (5)

(b)(6)

" wrote:

Can we discuss this EO with him? I' m still not sure how close hold this all is. (b) (6 )

Document ID: 0.7.12561 .27214

Document ID: 0.7.12561.27214

Document ID: 0.7.12561.27214

Document ID: 0.7.12561.27214

Document ID: 0.7.12561.27214

Document ID: 0.7.12561.27214

Document ID: 0.7.12561.27214

Document ID: 0.7.12561.27214

.IDIID• •{O_L_c)_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

From:
Sent: To: Subject:

(b) (6) {OLC)

Tuesday, January 17, 20171:29 PM

(b) (6)

,OLC)

RE: lllllltDISJIIII PLEASE READ

Oh no!

Fr o m :

(b) (6)

{OLC)

Sent: Tuesday, January 17, 20171:28 PM

Ole)<

Ack! I havelG)I&JJwith a similar problem!

Fro m: (b )(6) {OLC)

Sent: Tuesday, January 17, 20171:26 PM

at.Dll:JIIII- To: -
Subject: RE:

(Ol C} • PLEASE READ

(b)(6)

Got it. Right.

(b) (6)

OLC)

Yes, please!

(b) (5)

From: (b) (6) {OLC)

Sent: Tuesda

17 20171:24 PM

To:

(OLC} <

(b )(6)

·

Subject: RE: ,

-- PLEASE READ

I can send t hemWJitiJ]
Sorry, we should send themWJltiJ1 or not?

From:

(b) (6)

(OLC)

Sent: Tuesday, January 17, 20171:23 PM

(O l e ) <

- PLEASE READ

them tmJU Do you want me t o draft an email t o them or do you want t o? I want to send

After I'm off my

call, perhaps Qi>lm)and I could give you a call from his office?

Fr o m :

(b ) ( 6 )

(OLC)

Document ID: 0.7.12561.26909

S e n ~171:03PM

To:~

OlC} •

<

(b)(6)

•

Subject: RE:

(b) (5) -- PLEASE READ

(b) (6)
------

; Hart, Rosemary {Ole}

as well.

I'm not very familiar with that issue, but I figured

(b) (6)

; Hart, Rosemary (OLC}. _

an

From: (b ) (6 ) {Ole)

Sent: Tuesday, January 17, 201712:57 PM

To: Hart, Rosemary (OLC) <

(b)(6)

•

- PLEASE READ
(b) (5)

From: Hart, Rosemary {Ole)
Sent: Tuesday, January 17, 201712:49 PM OlC

(b) (6)

Ole}

(b) (6)

(Ole)

From: (b) (6) {Ole) Sent: Tuesday, January 17, 201711:49 AM To: Hart, Rosemary (OLC) <

<I

Subject: RE:

(b) (5) -- PLEASE READ

(b) (6)

{OLC)

Document ID: 0.7.12561.26909

Document ID: 0.7.12561 .26909

(b) (6)

~

(b) (6) (Ole)

I was wondering that, too.

From:

(b) (6)

Ole)

S e n ~ r y 17, 201711:25 AM

,__To:~ Cc: Hart, Rosema Subject: Re:

OlC}<. OLC <

(b) (5)
Could you see if you could find out anything about

(b) (5)

(b) (6)

Attorney-Adviser

~

Counsel

IIIIIIIIVI.IIUI

On Jan 17, 2017, at 11:22 AM,

(b) (6)

Ole) ·

(b) (6)

wrote:

Document ID: 0.7.12561.26909

Document ID: 0.7.12561 .26909

Document ID: 0.7.12561 .26909

Document ID: 0.7.12561 .26909

(b) (6)
From: Sent: To:
Cc: Subject:

OLC}

(b) (6) {OLC)
Tuesday, January 17, 2017 2:21 PM

-· (b) (6)

{O LC) (OLC)

RE: - question for you

From:

(b) (6 ) {OLC)

Sent: Tuesday, Ja~

To: ~ ~>; IIIIIGJmllll(OLC) ~

Cc:- -OLC)<

(b )(6 )

~

Subject: ~uestion for you

to)mJ]a nd ru>l(m

We have (b )(S)
-Basically, the question is

•uestion t hat we would love your views on. (b) (5)

Document ID: 0.7.12561.14691

(b) (5)
(b) (5)

(b) (5)
(b) (5)

From: Hart, Rosemary {OLC)

S e n ~ry 17, 20171:22 PM

To: ~

OLC)<

- PLEASE READ

a l Sure, loop him in. And

t oo.

(b) (6)

OLC)

Document ID: 0.7.12561.14691

Document ID: 0.7.12561.14691

Document ID: 0.7.12561.14691

Document ID: 0.7.12561.14691

Document ID: 0.7.12561.14691

Document ID: 0.7.12561.14691

•m•m•.{O_Lc_)_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

From: Sent: To: Cc: Subje ct:

(b) (6) {OLC)

Tuesday, January 17, 2017 3:14 PM

(b) (6) {OLC);- - ·

_

......,....U. J,,,.,~OLC)

RE: - question for you

(b) (5)

(b) (5)

UNI Tremendous thanks,

for your help on all this.

From:¥ ' 9 J{Ole)

Sent: ; e; :, January 17, 2017 3:08 PM

To:

(OlC)<

(b) (6)

•;UJml< (b) (6) •

Cc: -

{OLC)~

(b) (6)

•

Subject: RE: 111tuestion for you

(b) (6)
This is super helpful. Thank you!
Document ID: 0.7.12561.53655

(b) (5)

From: lti>M

Sent: Tuesday, January 17, 2017 2:30 PM

To: lllllltDDllll(OLC}<

Cc: -

OLC)<

Subject: RE:~ uestion for you

I was in the middle of an email saying that , but that it seemed like we have an in-house

From: (b)(6) OLC)

Sent: Tuesday, January 17, 2017 2:25 PM

To:

OlC <

(OLC) -
would be in a much better position than me to answ er, So count this as a "me too," with gratitude that

<

(b) (6)

·

What follows is my quick take.

Document ID: 0.7.12561.53655

Document ID: 0.7.12561.53655

Document ID: 0.7.12561.53655

Document ID: 0.7.12561.53655

Document ID: 0.7.12561.53655

Document ID: 0.7.12561.53655

Document ID: 0.7.12561.53655

Document ID: 0.7.12561.53655

(b) (6)

(OLC)

From: Sent: To: Subject:

(b) (6)

(OLC)

Tuesday, January 17, 2017 3:54 PM

(b) (6)

OLC); (b) (6)

RE: a : iuestion for you

(OLC); (b) (6) (OLC); (b) (6)

OK; I'm going to send it on.

From: (b) (6) Ole)

Sent: Tuesday, January 17, 2017 3:53 PM

Ole)< (Ole) <

(b) (6)

,

(b) (6)

,

This works from my perspective.
From: (b) (6) (Ole)
Sent: Tuesday, January 17, 2017 3:47 PM OlC)<

(b) (6)

•

To accommodate we could add the following (

(b) (5)

(b) (5)

(b) (5)

Although, this makes it more cumbersome.

From: ·eG)Jmll (Ole)

Sent: Tuesday, January 17, 2017 3:44 PM

T
< <

(b) (6)
(b) (6)
(b) (6)

• -Ol-e)<t i J I U J-
•

s

(b) (5).

you

-I likf'IMlc; approach also because

(b) (6)

(Ole)

;; 4 V OlC}
J k Ole}
(b) (5)

Subject: RE: ~ uestion fo r you

(Ole)<

(b)(6 )

·

(b) (6)

•

Document ID: 0.7.12561.14520

.···-~···~_....,...~. -~---~... ..~..---~· ...~.

Fr o m :

(b) (6)

(OLC)

(b) (6)

>·, (b) (6) OLC}<.

(b)(6)

.,

(b) (6)

(OLC) <

(b) (6)

•

(b)(5)
something like the following:

(b) (5)

I wonder if we could just state

From:

(b) (6)

(OLC)

•m.,.•_a.....,..yl;Jll!JIIII( Sent: Tuesday, January 17, 2017 3:32 PM

To: I I I I I I D B t > I I I I ( OLC} <

mmn<-

>;

(OLC) <

Ole) <
(b)(6)

(b)(6)
•

·

Subj ect: RE:~ uestion for you

So I've drafted

(b) (5)

If you all are ok, I'll send it on to Rosemary.

; I (b) (6)

(b) (6) •

OLC)

That is correct.

(b) (5)

From:

(b) (6)

OLC)

Sent: Tuesday, January 17, 2017 3:08 PM

To:

(b) (6)

OLC} <= = = =(b=) (6= ) = = =• (b) (6) {OLC}<_

(b) (6)

.:

Sounds good.

(b) (5)
(b) (5)

Document ID: 0.7.12561 .14520

From : I

(b) (6)

OLC)

. r. . . . . Sent: Tuesday, January 17, 2017 3:05 PM

(b) (6)

•

----

>

Subj ect~

you

- and I are thinking language on this.

(b) (5)

(b) (6) OLC) <.

(b) (6)

• ;mlJ

I'm going to try to draft some placeholder

From :

(b)(6)

(OLC)

Sent: Tuesday, January 17, 2017 2:56 PM

To:

(OLC

•tDGJJl<J

Subject: RE:

I did find this from

(b) (5)

(b) (6)

OLC} <.

(b)(6 )

•

From: IIIIIO>IG>IIII(OLC)

Sent: Tuesday, January 17, 2017 2:51 PM

To:

(b) (6 )

(OLC}<

(b) (6)

>·,

(b) (6 ) (OLC}

<

(b) (6)

•

II <

(b) (6)

Subject: RE:tlllliuestion for you

No, it isn't working for me either, and it wasn't working for .

his morning.

From:

(b) (6)

OLC)

S e n ~ry 17, 2017 2:50 PM

To: IIIIIIVl&W.all(OlC) <;

(b) (6)

•

(OLC) ~

Subject: RE: ~ uestion for you

(b)(6)

, (b) (6)

Am I the only one for whom Perceptive Search is not working?
duplicate

Document ID: 0.7.12561.14520

Document ID: 0.7.12561.14520

Document ID: 0.7.12561.14520

Document ID: 0.7.12561.14520

Document ID: 0.7.12561.14520

Document ID: 0.7.12561.14520

Document ID: 0.7.12561.14520

Document ID: 0.7.12561.14520

Document ID: 0.7.12561.14520

(b) (6)

OLC)

From: Sent: To: Subject: Attachments:

(b) (6)

OLC)

Tuesday, January 17, 2017 3:57 PM

Hart, Rosemary (OLC)
(b) (5)

-Near Final
(b) (5)

Document ID: 0.7.12561.2611 3

-IDlliJ-·(o_L_c1_____________________

From: Sent: To: Subje ct: Att achments:

(b) (6)

(OLC)

Tuesday, January 17, 2017 4:07 PM
MGJII Hart, Rosemary (OLC);
(b) (5) F&l

(b) (5)

~

30pm +1111.17).docx;

IIIIIWltDllll l -17-2017)... +rh.docx

(b) (5)

Near Final

Document ID: 0.7.12561.53718

(b) (6)
From: Sent: To: Subject:

{OLC}
(b) (6) (OLC)
Tuesday, January 17, 2017 4:25 PM
(b) (6) (b) (5) notes etc.

(b) (5) https:/ /

(b) (5)

Document ID: 0.7.12561.32291

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Tuesday, January 17, 2017 6:12 PM

(b) (6)

(OLC}

RE:

(b) (5)

Looking at this now.

From : I

(b) (6)

{Ole)

Sent: Tuesday, January 17, 2017 3:57 PM

To: Hart, Rosemary (Ole) <

(b)(6)

•

Subject:

(b) (5)

duplicate

Document ID: 0.7.12561.26091

Gannon, Curtis (OSG)

From: Sent: To: Subject:

Gannon, Curtis (OSG)
Tuesday, January 17, 2017 8:48 PM Hart, Rosemary (OLC}
RE: Signing schedule

Even better!

From: Hart, Rosemary {OLC)

Sent: Tuesday, January 17, 2017 8:48 PM

To: Gannon, Curtis (OSG) <

(b)(6 )

Subjed:: RE: Signing schedule

And they will follow up

·
(b) (5)

From: Gannon, Curtis (OSG) Sent: Tuesday, January 17, 2017 8:47 PM To: Hart, Rosemary (Ole) ~ Subjed:: RE: Signing schedule
Excellent. Thanks!
From: Hart, Rosemary (Ole) Sent: Tuesday, January 17, 2017 8:43 PM To: Gannon, Curtis(OSG) ~ Subject: Signing s-ehedule
Just got off a long call with Steve and Scott. We now have a list re: issuance plan for the first week. This will help us focus our resources during the next several days.
Note: We only issue paperwork for the EOs, but we approve via email on all the others. I've highlighted the
EOs for the first couple of days. Need to turn to more immediate stuff, but will send you an update later
tonight or tomorrow.
Frid ay:

(b) (5)
Document ID: 0.7.12561.46127

Monday

Wednesday:
EW•

Thursday:

(b) (5)

I.

(b) (5)

(b) (5)

Monday:

(b) (5)

(b) (5)

Document ID: 0.7.12561.46127

(b) (6)
From: Sent: To: Subject: Attachments:

(OLC)

(b) (6)

(OLC)

Wednesday, January 18, 201 7 10:10 AM

Hart, Rosemary (OLC)

RE:

(b) (5)

From :

(b) (6)

(OLC)

Sent: Tuesday, January 17, 2017 3:57 PM

To: Hart, Rosemary (OLC) <

Su bj ec t:

duplicate

-Near Final

Document ID: 0.7.12561.25961

- t p J m - .(O_L_c)_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

From: Sent: To: Subject:
Attachments:

(b) (6)

{OLC)

Wednesday, January 18, 2017 10:33 AM

Hart, Rosemary (OLC)

RE: (1.16.16)

-Near Final

(b)(5)

From: Hart, Rosemary {Ole)

Sent: Wednesda , Janua 18, 201710:30 AM

To:

(OLC}<

Subject:

-tlll.18}+rh

Looks good. See my tweaks to

(b) (5)

-Near Final (1.16.16)+. 730pm Accurate? Please edit as necessary.

Document ID: 0.7.12561.25922

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Wednesday, January 18, 2017 1:27 PM

Gannon,Curtis(OSG)
RE: (1.16.16) + OLC {118 2017)

(b) (5)

-Near Final

Will do. Thanks for responding.

From : Gannon, Curtis (OSG)

Sent: Wednesday, January 18, 20171:22 PM

To: Hart, Rosemary (OLC) <

(b) (6)

Subject: Re:

(b) (5)

18 2017)

-Near Final (1.16.16} + OLC (1

And I won't have more time to look at it this afternoon, so please proceed as you see f it with Steve. {I'm on my way to his office to interview a DAAG candidate.)

On Jan 18, 2017, at 1:18 PM, Gannon, Curtis {OSG) <

(b) (6)

"' wrote:

Thanks, Rosemary. I haven't done any research, but your proposal makes sense to me.

On Jan 18, 2017, at 10:45 AM, Hart, Rosemary {OLC) <

(b) (6)

wrote:

y can j ust go ahead.

(b) (5)
p g
(b) (5)

let me know what you feel comfortable doing on this.

Thanks,

Rosemary

<

(b) (5)

(1.16.16) + OLC (1 18 201 i ).docx>

-Near Final

Document ID: 0.7.12561.45949

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Wednesday, January 18, 2017 1:28 PM

Gannon,Curtis(OSG)
RE: (1.16.16) + OLC {1 18 2017)

(b) (5)

thanks

From: Gannon, Curtis (OSG)

Sent: Wednesday, January 18, 20171:18 PM

To: Hart, Rosemary (OLC) <

(b) (6)

Subject: Re:

(b) (5)

18 2017)

-Near Final Near Final (1.16.16} + OLC (1

Document ID: 0.7.12561.45950

(b) (6)

OLC)

From: Sent: To: Cc: Subject: Attachments:

(b) (6)

{OLC)

Wednesday, January 18, 201 7 1:29 PM
(b) (6)

Hart, Rosemary (OLC}

F&Ls

EO Form and Legality -

(b) (5)

ru)IEJJ.docx; EO Form and Legality -

(b) (5)

(b ) ( 5)

docx; EO Form and Legali -

docx; EO Form and Legality -

I think, but am not sure, that this is all my remaining F&Ls except the one on (b) (5)
let me know.

(b) (5) If I'm missing any, please

Document ID: 0.7.12561.14191

••• From: Sent: To: Subject:

(b) (6 )

Wednesday, January 18, 2017 1:34 PM

(b) (6)

(OLC}

RE: F&Ls

Awesome-thanks very much!

From:

(b) (6)

Ol e)

Sent: Wednesday, January 18, 20171:29 PM

To:e G > J l d l ~

Cc: Hart, Rosemary {Ole)<

(b) (6)

,

Subject: F&Ls

duplicate

Document ID: 0.7.12561.13669

(b) (6)
From: Sent: To: Subject:
Attachments:

OLC)

(b) (6)

OLC)

Wednesday, January 18, 201 7 1:50 PM

Hart, Rosemary (OLC) RE: (1.16.16H lill730pm +.

(b) (5) 1.18) + rh

-Near Final Near Final

Getting closer, I hope!

From: Hart, Rosemary (Ole)

Sent: Wednesday, January 18, 201710:30 AM

To:

'OLC} <

Subject:

+1111.1s)+rh

duplicate

-Near Final (1.16.16)-tilt30pm

Document ID: 0.7.12561.25756

(b) (6)

OLC)

Fro m: Sent: To : Subject:
Attachments:

(b) (6)

{OLC)

Wednesday, January 18, 2017 2:17 PM

Hart, Rosemary (OLC)

RE:

(b) (5)

(1.16.16)+ill730pm -11111.18) + rh+llill14Sp)

-Near Final Near Final

Ugh! I keep having version problems. I'd added something to that effect, but I must not have sent you the right one. What you wrote seems good. 11ve also fixed a weird highlighting glitch in another comment.

To : Subject:
~- 1.18) + rh+-

145p)

Ithought we should flag

(b) (5)

-Near Final (1.16.16)+ili730pm See attached.

Document ID: 0.7.12561.25736

-W•W'111111<.o_L_c1_______________________

From: Sent: To: Subject:
Attachments:

(b) (6)

(OLC)

Wednesday, January 18, 2017 2:38 PM

Hart, Rosemary {OLC)

RE: (1.16.16)+

Near Final

(b) (5)

(which I've highlighted in blue Just so you can see it).

-Near Final {1.16.16)+. 730pm

Document ID: 0.7.12561.25582

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Wednesday, January 18, 2017 8:57 PM

(b) (6)

(OLC}

Read: Final (1.16.16)+11730pm

Near

Your messag.e

To: Hart, Rosem a

Subject: RE:

Near Final (1.16.16)-

(1.18)+ 0LC

Sent: Wednesday, January 18, 2017 2:37:56 PM (UTC-05:00) Eastern Time (US & Canada)

w as read on Wednesday, January 18, 2017 8:55:51 PM (UTC-05:00) Eastern Time (US & Canada).

+I I 730pm

Document ID: 0.7.12561.24978

-m1m1a111(.o_L_c1______________________

From: Sent: To: Subject:

(b)(6)

(OLC)

Thursday, January l9, 2017 11:09 PM

Hart, Rosemary (OLC)
Re: (b) (5)

It sounds like we are waiting for
(b) (6) Attorney-Adviser Office of Legal Counsel
(b) (6)

(b) (5)

On Jan 19, 2017, at 10:50 PM, Hart, Rosemary (OLC) <
(b) (S)

(b) (6)

I
• wrote:

Document ID: 0.7.12561.24974

Document ID: 0.7.12561.24974

Hart, Rosemary (OLC)

From: Sent: To: Subject:
Attachments:

Hart, Rosemary (OLC}

Thursday, January l9, 2017 11:34 PM

(b) (6 )

{OLC}

FW:

(b) (5)

(1.16.16)+ OLC again (116 2017) (1).docx

(b) (5)

(1.16.16)+ OLC again (116 2017) {1).docx

If you are awake....

Near Final Near Final

Document ID: 0.7.12561.24964

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Friday, January 20, 2017 8:43 AM

(b) (6)

,OLC}

RE:

(b) (5)

(1.1 6.16)+ OLC again (1 16 2017) (1) + RH

-Near Final

Thanks!

He had been working from an earlier version, I think.

From:

(b) (6)

{ O LC)

Sent: Friday, January 20, 2017 8:06AM

To: Hart, Rosemary (OLC) <

(b) (6)

•

Subject: RE:

(b)(5)

again (116 2017) (1) + RH

Near Final {1.15.15)+ OLC

The version Steve et al reviewed was not our previous final version, so I've added in the changes we had previously discussed. I also added comments/edits in response to this round, and t ried to clean things up a bit where possible.

From : Hart, Rosemary {OLC)

Sent: Friday, January 20, 201712:28 AM

To:

(OLC} <

Subject:

16 2017) (1) + RH

-Near Final (1.15.16}+ OLC again (1

. , started a redline in response to this, but would appreciate your review and input. Maybe we could talk tomorrow at some point? Thanks, Rosemary

Document ID: 0.7.12561.24925

 
 U.S. Department of Justice
Office of Legal Counsel
Washington, D. C. 20530
January 16, 2018
Charlie Savage The New York Times savage@nytimes.com
Re: FOIA No. FYl 7-070; N.Y. Times, et al. v. DOJ, No. 17 Civ. 1946 (S.D.N.Y.)
Dear Mr. Savage:
This letter partially responds to your January 28, 2017 Freedom oflnformation Act ("FOIA") request to the Office of Legal Counsel ("OLC"), seeking "all e-mails, memos, and other documents related to[:] 1. Office of Legal Counsel review of proposed Trump administration executive orders for form and legality, including during the transition period[;] and 2. Office of Legal Counsel review of other proposed Trump White House matters, including during the transition period," through January 28, 2017. As you know, the request is also the subject of the above-captioned litigation, and the request has been narrowed in certain ways pursuant to agreement through counsel.
Since the last partial response, we have processed 372 pages ofresponsive records. We have enclosed 46 pages with material redacted as exempt from disclosure pursuant to FOIA Exemption Five, 5 U.S.C. § 552(b)(5), and pursuant to FOIA Exemption Six, 5 U.S.C. § 552(b)(6). For your information, Exemption Five exempts material protected by the attorneyclient, deliberative process, and presidential communications privileges, as well as the attorney work product doctrine and other privileges. Exemption Six exempts material the disclosure of which would constitute a clearly unwarranted invasion of personal privacy. We have withheld the remaining 326 pages in full pursuant to Exemption Five, and in part pursuant to Exemption Six. We have determined that none of the withheld material is appropriate for discretionary release. We are continuing to process responsive records.
For your information, Congress excluded three discrete categories oflaw enforcement and national security records from the requirements of the FOIA. See 5 U.S.C. § 552(c). This response is limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.
You may contact Assistant U.S. Attorney Rebecca Tinio, at 212-637-2774, for any further assistance and to discuss any aspect of your request. Additionally, you may contact the Office of Government Information Services ("OGIS") at the National Archives and Records Administration to inquire about the FOIA mediation services they offer. The contact information for OGIS is as follows: Office of Government Information Services, National Archives and Records Administration, Room 2510, 8601 Adelphi Road, College Park, Maryland 20740-6001,

e-mail at ogis@nara.gov; telephone at 202-741-5770; toll free at 1-877-684-6448; or facsimile at 202-741-5769.
Although your request is the subject of ongoing litigation, and administrative appeals are not ordinarily acted upon in such situations, I am required by statute and regulation to inform you of your right to file an administrative appeal. You may administratively appeal by writing to the Director, Office of Information Policy ("OIP"), United States Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, DC 20530-0001, or you may submit an appeal through OIP's FOIAonline portal by creating an account on the following web site: https://foiaonline.regulations.gov/foia/action/public/home. Your appeal must be postmarked or electronically transmitted within 90 days of the date of my response to your request. If you submit your appeal by mail, both the letter and the envelope should be clearly marked "Freedom of Information Act Appeal."
Sincerely,
/4//!~
Paul P. Colborn Special Counsel Enclosures
cc: Rebecca S. Tinio Assistant United States Attorney Southern District of New York Benjamin H. Torrance Assistant United States Attorney Southern District of New York
2

Hart, Rosemary (OLC)

From: Sent: To: Cc: Subject:

Hart, Rosemary (OLC}

Thursday, December 1 5, 201 6 10:16 PM

(b) (6)

(OLC}

Koffsky, Daniel L (OLC)

{12-11-2016)

Thanks,.

RH

On Dec 15, 2016, at 9:59 PM,

This

(b) (5)

(b) (6)

(OLC) <

(b) (6)

and adds some conforming language.

• wrote:

From: Koffsky, Daniel L (OLC} Sent : Thursday, December 15, 2016 7:15 PM To: Hart, Rosemary (OLC) Cc: Subject: Re:
+ rh 230 pm
That would be good.
Sent from my iPhone
On Dec 15, 2016, at 6:51 PM, Hart, Rosemary (OLC) <
(b) (5)

(b) (6)

(12-11-2016). (003)
· w rot e:

From: Koffsky, Daniel L{Ole)

Sent: Thu rsday, December 15, 2016 6:33 PM

To: Hart, Rosemary {Ole}<

(b) (6)

~

Cc:

(b) (6)

(ml'iE

(D) (6)

Subject: RE·

(b) (5)

(12-

ll-2016)i(b' ) (o) 11

I •

(b) (5)

(b) (5)

From: Hart, Rosemary (OLC) S t Th d D b 15 2016 6 25 PM
duplicate

Document ID: 0.7.13767.48104

Document ID: 0.7.13767.48104

Document ID: 0.7.13767.48104

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Thursday, December 1 5, 201 6 10:51 PM

(b) (6)

(OLC}

Re:

(b) (5)

(12-13-16) +illlli1+ rh

Sounds good.

On Dec 15, 2016, at 10:48 PM,

(b) (6)

! (OLC} •

(b) (6)

upMJeJII That's helpful, thanks. I'll finish

before turningtothetmJII EO.

> wrote:

From: Hart, Rosemary (OLC}

Sent: Thursday, December 15, 2016 10:06 PM

To:

( OLC)

Subject: Re:

(12-13-16) +111i1+ rh

I need to do t hem both. I thought I would work on the EOs the first t wo hours and then switch to ODll:)] until we send them out.
I am only sending Steve the ones from Batch 1. So not thelO>IEJI one.

On Dec 15, 2016, at 9:52 PM,

(b) (6)

{OLC} •

(b) (6)

wrote:

(b) (5)

will look through the m all tomorrow .

I know you're trying t o Which is your priority?

(b) (5)

and EOs back to Steve tomorrow.

from : Hart, Rosemary (OLC) Sent: Thursday, December 15, 2016 6:30 PM
(OLC} (12- 13-16) +111i1+ rh
Just a few addit ional edits, and an attempt at a response to your question.

Document ID: 0.7.13767.48090

Hart, Rosemary (OLC)

From: Sent: To: Cc: S u b j e ct:

Hart, Rosemary (OLC}

Friday, December 16, 2016 6:56 AM

(b) (6)

(OLC}

Koffsky, Daniel L(OLC)

Re:

(b) (5)

- - {003) + rh 230 pm

Yes, let's talk about that

(b) (5)

today.

On Dec 16, 2016, at 6:48 AM,

(b) (6)

(OLC) •

(b)(5)

(b) (6)

I (12-11-2016) > wrote:

(b) (6)
Attorney-Adviser
Office of Legal Counsel (b) (6)

On Dec 15, 2016, at 9:59 PM,

(b) (6)

(OLC} •

(b) (6)

>

wrote:

Document ID: 0.7.13767.48074

Document ID: 0.7.13767.48074

Document ID: 0.7.13767.48074

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Friday, December 16, 2016 1 0:04 AM

(b ) (6 )

i (OLC}

RE:

(b) (5)

(12-13-16) +illlli1+ rh

OK - Just remembered that you are doing[IDlli f irst. I will continue working on the EOs and talk to you
about them when you have a break.

From :

(b) (6)

(Ole)

Sent: Thursda , December 15. 201610:49 PM

Document ID: 0.7.13767.47720

From: Sent: To: Subject: Attachments:

MQ>lmJl1

Friday, December 16, 2016 10:48 AM

Hart, Rosemary (OLC}

(b ) ( 5 )

orders

(b) (5)

olc.docx;

-

(12-11-2016) + olc.docx

(b) (5)

(12-11-2016) +

Rosemary: I'm attaching the

(b) (5)

I orders in a cleaned up

redline form that would be ready for transmittal if everything looks good to you. You may want to take a

quick look at the comment bubbles on

that I've added to implement our discussions

yesterday (see new comment on page 1 and revised comment about '

:" on page 2).

You may also want to look at the comment I added to the

(b) (5)

I order regarding the

(b) (5)

Thanks!

Document ID: 0.7.13767.57676

- -·(O_L_c)_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

From: Sent: To: Subject:
Attachments:

(b) (6)

(O LC)

Friday, December 16, 2016 11:04 AM

Hart, Rosemary {Ol e)

RE:

(b) (5)

- (003) + rh 230 pm

(b) (5)
- (003) + rh 230 +llli 10pm + rh 9 am +111i111am.docx

I (12-11-2016) I (12-11-2016)

This strengthens the

(b) (5)

comment.

From: Hart, Rosemary {OLC)

Sent: Fri day, December 16, 201610:05 AM

To:

(Ole} •

(b) (6)

>

Subject: RE:

(b)(5)

pm

No-that's OK. Just come when you have a break.

(12-11-2016)- 1{003) + rh 230

From:

(b) (6 )

{OlC)

Sent: Fri day, December 16, 201610:04 AM

To: Hart, Rosemary (Ole) •

(b) (6 )

Subject: RE:

(b) (5)

pm

(12-11-2016}- 1{003) + rh 230

Sorry- I've been in t he SCIF working onru>M I can come to you in 2 minutes.

From: Hart, Rosemary {Ole)

Sent: Fri day, December 16, 201610:03 AM

To:

{OlC} •

(b) (6)

Subject: RE:

(b) (5)

pm

(12-11-2016)- 1{003) + rh 230

Ar e you around? I came by your office a couple of times but missed you. I wanted to follow up on a coupl e of your documents.

From :

(b) (6 )

{Ole)

Sent: Fri day, December 16, 2016 9:42 AM

To: Hart, Rosemary (Ole) •

(b) (6 )

Subject: RE:

(b) (5)

pm

Koffsky , Daniel L(Ole} ,

(b)(6) (12-11-2016)-

> 1(003) + rh 230

I think you' re right-

(b) (5)

Document ID: 0.7.13767.47697

From: Hart, Rosemary (OLC)

Sent: Friday, December 16, 2016 9:20 AM

To:

(OLC); Koffsky, Daniel L (OLC)

Subject: RE:

I tweaked t he comment

(b)(5)

Also,

(b) (5)

( 12-11-2016}- 1(003} + rh 230 pm

From:

(b)(6)

(OLC)

Sent: Friday, December 16, 2016 6:48 AM

Document ID: 0.7.13767.47697

Document ID: 0.7.13767.47697

Document ID: 0.7.13767.47697

From: Sent: To: Subject:
Attachments:

MWUII

Friday, December 16, 2016 11:24 AM

Hart, Rosemary {O l e)

RE: + olc 12 16 2016

(b) (5)

(b) (5)

ale 12 16 2016.docx

I (12-11-2016) I {12-11-2016) +

Thank you for catching that! All of your additions look good to me, and I've deleted the highlighting in the attached redline.

From: Hart, Rosemary (OLC)

Sent: Friday, December 16, 201611:16 AM
To:-UUmii1, (b) (6)

Subject:

(b)(5)

I l l: This looks gre at.

(12-11-2016) + olc 1216 2016 (b) (5)

Document ID: 0.7.13767.57573

- -·(O_L_c)_- - - - - - - - - - - - - - - - - - -

From: Sent: To: Subject: Attachments:

(b) (6)

! (OLC)

Friday, December 16, 2016 11:29 AM

Hart, Rosemary (OLC)

RE:

(b) (5)

(12-13-16) +i11111+ rh

(b) (5)

. (12-13-16) +i11111+ rh +i111111130am.docx

This revises t he comment

(b) (5)

From: Hart, Rosemary {OLC)

Sent: Thursday, December 15, 2016 6:30 PM

To: Subject:

+. + •(OLC} •

(b) (6)

>

(12-13-16}

rh

Just a few additional edits, and an attempt at a response to your question.

Document ID: 0.7.13767.47674

Hart, Rosemary (OLC)

From: Sent: To: Subject: At t a ch m e nt s:

Hart, Rosemary (OLC}

Friday, December 16, 2016 11:46 AM
emxae

(b) (5)

(12-13-16) + OLC (12 16 2016)

(b)(S)

. (12-13-16) + OLC (12 16 2016).docx

Here is theM$IE>II EO, wittll'sedits. No rush on this, as this is in Batch 2.

Document ID: 0.7.13767.57568

Hart, Rosemary (OLC)

From: Sent: To: Subject: At t a ch m e nt s:

.....Hart, Rosemary {Ole)
Friday, December 16, 2016 11:49 AM

(b) (5) (b) (5)

(12-13-16) + OLC (12 16 2016) (12-13-16) + OLC (12 16 2016).docx

Use this one. I adjusted

(b) (5)

Document ID: 0.7.13767.57564

Hart, Rosemary (OLC)

From: Sent: To: Cc: S u b j e ct:

Hart, Rosemary (OLC}

Friday, December 16, 2016 11:50 AM

Koffsky, Daniel L (OLC}

(b ) (6 )

: (OLC}

RE: + OLC 1 2 16 2016

(b) (5)

I (12-11-2016)

That makes sense. Thanks-this looks good.

From: Koffsky, Daniel L (OLC}

Sent: Friday, December 16, 201611:48 AM

To: Hart, Rosemary (OLC) •

(b)(6 )

Cc:

: (OLC) •

(b) (6)

>

Subject: RE:

(b) (5)

(b) (5)

i. See below.

(12-11-2016) + OLC 1216 2016

From: Hart, Rosemary {OLC}

Sent: Friday, December 16, 2016 11:31 AM

To: Koffsky, Daniel L {Ole) •

(b)(6 )

Cc:

(b) (6 )

: (OLC) •

(b) (6)

Su b j e ct:

(b) (5)

> {12-11-2016) + OLC 1216 2016

Dan: Here is the final that. and I propose sending. The comment on

(b) (5)

,now reads:

(b) (5)

Do you think this is OK?

Document ID: 0.7.13767.47549

Hart, Rosemary (OLC)

From: Sent: To: Subject:
Att achments:

.,,..Hart, Rosemary (OLC}
Friday, December 16, 2016 12:20 PM

OLC 12 16 2016 OLC 12 16 2016.docx

(b) (5) (b) (5)

This is thellQDJI EO.

(12-11-2016) + I (12-11-2016) +

Document ID: 0.7.13767.57308

Hart, Rosemary (OLC)

From: Sent: To: Subject:
Att achments:

.,,..Hart, Rosemary (OLC}
Friday, December 16, 2016 12:22 PM

OLC 12 16 2016 OLC 12 16 2016.docx

(b) (5) (b) (5)

IDJEDIagain, with

(b) (5)

slightly revised.

(12-11-2016) + I (12-11-2016) +

Document ID: 0.7.13767.57305

Hart, Rosemary (OLC)

From: Sent: To: Subject:
Att achments:

.,,..Hart, Rosemary {Ole)
Friday, December 16, 2016 1:06 PM

OLC 12 16 2016 OLC 12 16 2016.docx

(b) (5) (b) (5)

Ipromise - no more tinkering!

{12-11-2016} + (12-11-2016) +

Document ID: 0.7.13767.57290

Hart, Rosemary (OLC)

From: Sent: To: Subject:
Att achments:

.,,..Hart, Rosemary (OLC}
Friday, December 16, 2016 1:17 PM

olc 12 16 2016 olc 12 16 2016.docx

(b) (5) (b)(5)

I found a typo in one of my comments, so I fixed that. Also, made title all caps.

(12-11-2016) + . (12-11-2016) +

Document ID: 0.7.13767.57285

Hart, Rosemary (OLC)

From: Sent: To: Subject: At t a ch m e nt s:

Hart, Rosemary {Ole)

Friday, December 16, 2016 1:18 PM

-WIUII

(b) (5)

(b) (5)

2016.docx

Another f inal.

(12-11-2016) + OLC 12 16 2016 (12-11-2016) + OLC 12 16

Document ID: 0.7.13767.57283

Hart, Rosemary (OLC)

From: Sent: To: Subject: At t a ch m e nt s:

Hart, Rosemary {Ole)
Friday, December 16, 2016 2:09 PM
MWUII
(b) (5)
(b)(S)

(12-11-2016) +111+ rh
1(12-11-2016) +111+ rh.docx

Good edits! This one was a bit messy. I've tried to respond to you r questions and have added some additional edits.

Document ID: 0.7.13767.57257

- -·(O_L_c)_- - - - - - - - - - - - - - - - - - -

From: Sent: To: Subject: Attachments:

(b) (6)

i (OLC)

Friday, December 16, 2016 2:18 PM

Hart, Rosemary (OLC)

RE:

(b) (5)

21 7 p m . d o c x

(b) (5)

+. + : (12-11-2016)

rh

: (12-11-2016) +11111+ rh +ill

From: Hart, Rosemary {Ole)

Sent: Friday, December 16, 2016 2:17 PM

To:

• {OLC)

Subject: RE:

(b) (5)

That would be great. Thanks!

+. 1 (b) (6)

, {12-11-2016}

+ rh

From:

(b) (6)

I (OLC}

Sent: Friday, December 16, 2016 2:16 PM

To: Hart, Rosemary (OLC} •

(b)(6)

Subject: RE:

(b) (5)

Yes, but I'm conforming the comment about

+. 1 ,(12-11-2016}

+ rh

(b) (5)

, so give me a minute.

From: Hart, Rosemary {OLC}

Sent: Friday, December 16, 2016 2:16 PM

To:

• (OLC} •

Subject: FW:

(b) (5)

This is the last version I recall. Correct?

(b) (6)

4. 1 >

(12-11-2016)

+ rh

From: Hart, Rosemary {OLC)

Sent: Wednesday, December 14, 2016 8:49 PM

To:

{OLC} •

(b) (6)

Subject:

(b) (5)

>
(12-11-2016} +Ill + rh

. : I liked all your edits and questions. In the attached redline, I have responded to your question by

providing an outward-facing comment and have added some additional edits.

(b) (5)

Happy to discuss.
Thanks, Rosemary

Document ID: 0.7.13767.47531

Hart, Rosemary (OLC)

From: Sent: To: Subject: At t a ch m e nt s:

Hart, Rosemary {Ole)
. ,... Friday, December 16, 2016 2:27 PM

2016.docx

(b) (5) (b) (5)

Another f inal.

: (12-11-2016) + OLC 12 16 2016 ; {12-11-2016) + OLC 12 16

Document ID: 0.7.13767.57247

From: Sent: To: Subject: Attachments:

.....
Friday, December 16, 2016 2:45 PM Hart, Rosemary {O le)
(b) (5) (b) (5)

(12-11-2016) + olc 1 {12-11-2016) + olc.docx

Rosemary: A near-final version of this redline for your review. The yellow highlighting denotes where I added text.

Document ID: 0.7.13767.57180

Hart, Rosemary (OLC)

From: Sent: To: Subject: At t a ch m e nt s:

.....Hart, Rosemary {Ole)
Friday, December 16, 2016 2:50 PM
(b) (5) (b) (5)

(12-11-2016) + olc 1 (12-11-2016) + olc.docx

Those look good. Thanks!

Document ID: 0.7.13767.57155

From: Sent:

MW•WM
Friday, December 16, 2016 4:04 PM

To:

Hart, Rosemary (OLC}

Subject:

RE: Executive Orders for OLC Review (Part 1)

Attachments:

(b) (5)

(12-11-2016) + olc 12 16

2016.....docx;

(b) (5)

-

(....docx;

(b) (5)

-

{12-11-20....docx;

(b) (5)

-

(12-11-20....docx;

(b) (5)

(12-

11-2016) + OLC 12 16 2....docx;

(b) (5)

(12-11-2016) + OLC 12 16 ....docx

Rosemary: I' m attaching cleaned up redlines for the six EOs in the first batch. I looked at thelll PM and didn't think that any formatting changes, so Ithink all of this is ready for transmittal. Thanks[

From: Hart, Rosemary {Ole) Sent: Monday, December 12, 2016 10:00 AM

Document ID: 0.7.13767.5711 7

duplicate
Document ID: 0.7.13767.57117

From: Sent: To : Subject:
Attachments:

MUWM1

Friday, December 16, 2016 4:18 PM

Hart, Rosemary (OLC}

RE: 2016

(b) (5)

2016.docx

(b) (5)

: (12-11-2016) + OLC 12 16 : (12-11-2016) + OLC 12 16

You're right! I've made that change in this version {as well as added underlining under the "sec. X" parts throughout to match the other orders).

From: Hart, Rosemary (OLC)

Sent: Friday, December 16, 20164:09 PM

To:MG>Ja1,

(b) (6 )

Subject:

(b) (5)

Reading through this one,

(12-11-2016} + OLC U 16 2016
(b) (5)

Document ID: 0.7.13767.56823

Hart, Rosemary (OLC)

From: Sent: To: Cc: Subject: Attachments:

Hart, Rosemary (OLC}

.,.,. Monday, December 19, 2016 9:48 AM

(b) (6)

(OLC}

FW: Draft executive order,

(b) (5)

(b) (5)

(12-18-2016).docx; ATT00001.htm

tml(I: Another one for review.

(b) (5)

Thanks, Rosemary

Document ID: 0.7.13767.35820

___,----------------------------------

From:

waue

Sent:

Monday, December 1 9, 2016 9:58 AM

To:

Hart, Rosemary {Ole)

Subject:

RE: lllllfDmllll E0

Yes, will do. Thanks!

From: Hart, Rosemary {Ole)

Se nt: Monday, December 19, 2016 9:57 AM

To:•G>J-1,

(b) (6 )

Subject: FW:

I l l: Could you please review this one? Just looking through this quickly,

(b) (5)

RH

Document ID: 0.7.13767.56319

- -·(O_L_c)_- - - - - - - - - - - - - - - - - - -

From: Sent: To:
Cc: Subject:

(b) (6)

! (OLC)

Monday, December 19, 2016 10:16 AM

Hart, Rosemary (OLC)
MWIWM
RE: Another EO

Sure.

From: Hart, Rosemary {OLC)

Sent: Monday, December 19, 201610:14AM

To:iiiiiiiiiiiiiiieiiiiiiii

i { 0 LC}

(b) (6)

>

Cc:E I -1·

(b) (6)

>

Subject: Another EO

i i: Could you please review the attached draft? I would like to send comments back this week if at all
possible. Thanks, Rosemary

Document ID: 0.7.13767.47188

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Monday, December 19, 2016 11:07 AM

Koffsky, Daniel L (OLC); llllll:>DIIII

RE: Draft executive order,

(b)(5)

Let's meet in 5 minutes. I'll print out the latest order.

From: Koffsky, Daniel L (Ol e)

Sent: Monday, December 19, 201611:06 AM

To: Hart, Rosemary {Ole) •

(b) (6)

Subject: RE: Draft executive order,

(b) (5)

I can accommodate any time today.

•

(b) (6)

From: Hart, Rosemary {Ole)

Sent: Monday, December 19, 2016 11:05 AM

To:E J W 1 i1<

>; Koffsky, Daniel L (OLC) •

Subject: RE: Draft executive order,

(b) (5)

I have a call from 2-3 but am otherwise flexible.

Dan: What works for you?

Rosemary

(b)(6 )

From:a e > U J l1

Sent: Monday, December 19, 201610:19 AM

To: Hart, Rosemary {Ole) •

(b) (6)

Koffsky, Daniel L {Ole} ,

Subject: RE: Draft executive order,

(b) (5)

I have a 10:30 call but am ot herwise free today.

(b)(6)

From: Hart, Rosemary (OLC)

Sent: Monday, December 19, 2016 10:16 AM

To: Koffsky, Daniel L {OLC) •

(b)(6)

Subject: FW: Draft executive order,

(b) (5)

We should discuss when convenient.

•

(b)(6)

Document ID: 0.7.13767.50646

Document ID: 0.7.13767.50646

duplicate
Document ID: 0.7.13767.50646

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Monday, December 19, 2016 12:23 PM

(b) (6) i (OLC}

RE: Draft executive order,

(b) (5)

I can find it and send it.

From : (b) (6) : {Ole)

Sent: Monday, December 19, 201612:22 PM

To: Hart, Rosemary {Ole) •

(b)(6)

Subject: RE: Draft executive order,

(b) (5)

I can easily tra~
-- -·~
Offic e o f Lega l Counse l (b) (6)

, but you also mentioned Do you by any chance have that handy?

(b) (5)

From : Hart, Rosemary {Ole)

Sent : Monday, December 19, 201612:15 PM

To:

! (Ole) •

(b)(6)

>

Subject: FW: Draft executive order,

(b) (5)

Here is the electronic version. Thanks!

Rosemary

Document ID: 0.7.13767.42004

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Monday, December 19, 2016 12:32 PM

-

(OLC}

Emaiiing - llllltDll:Jllll.pdf

Here is the memo I was thinking of -

(b) (5)

(b) (5)
-·

Document ID: 0.7.13767.42003

From: Sent: To: Subject: Attachments:

IIIIIIDIDII
Monday, December 19, 2016 2:32 PM
Hart, Rosemary (OLC} RE: EOs for OLC
(b) (5)

Rosemary: Attaching a red line of thettillll EO. Thanks!

From: Hart, Rosemary {OLC) Sent: Thursday, December 15, 20161:15 PM

(12-14-2016) + a .docx

Document ID: 0.7.13767.55854

Document ID: 0.7.13767.55854

Hart, Rosemary (OLC)

From: Sent: To: Subject:

Hart, Rosemary (OLC}

Monday, December 19, 2016 3 :18 PM

(b)(6 )

(OLC}

RE: Another EO

I had not thought of that. We usually wait until they are final and we know they are going forward. But if you have time, and just hang onto the paperwork, it could save time later if a bunch of them go forward. It's really up to you and your workload.
Thanks, Rosemary

F r om :

(b) (6)

(Ole)

Sent: Monday, December 19, 2016 3:07 PM

To: Hart, Rosemary (Ol e) •

(b) (6)

Subject: RE: Another EO

Here are my comments. Are we supposed to be preparing F&L memos for these EOs as we go as well?

From: Hart, Rosemary {OLC) Sent: Monday, December 19, 201610:14AM

Document ID: 0.7.13767.47152

From: Sent: To: Subje ct: Att achments:

-mm•
Tuesday, December 20, 2016 1:56 PM
Hart, Rosemary {O le)
RE: lllllfDmllll E0
(b) (5) {12-18-2016) + ii11.docx

Rosemary: Here's a draft redline.
-- ·Thanks,

(b) (5)

From: Hart, Rosemary (OLC) Sent: Monday, December 19, 2016 9:57 AM

Document ID: 0.7.13767.55385

duplicate
Document ID: 0.7.13767.55385

From: Sent: To: Subject: Attachments:

-mm•
Wednesday, December 21, 2016 10:42 AM

Hart, Rosemary {O le)

RE:

(b) (5)

(b) (5)

2 0 1 6 ).d ocx

This looks great, Rosemary. sentence now reads:

(b) (5) (b) (5)

+. + i (12-14-2016)

rh

; {12-14-2016) + olc (12-21-

The Order has all of our internal comments removed and should be ready for transmittal. Thanks!

From: Hart, Rosemary (Ole)

Sent: Wednesday, December 21, 2016 9:57 AM

To:

• = Subject:

(12-14-2016) +. I+ rh

This looks good! Iadded a few technical edits, plus

(b) (5)

let me know what you think. Rosemary

Document ID: 0.7.13767.55360

Hart, Rosemary (OLC)

From: Sent: To: Subject:
Att achments:

.,,..Hart, Rosemary (OLC}
Wednesday, December 21, 2016 11:31 AM

2016) 2016).docx

(b) (5) (b ) ( 5 )

Thnx, RH

(b) (5) . Let me know if you are OK with this change.

, (12-14-2016) + olc {12-21, (12-14-2016) + ale (12-21-

Document ID: 0.7.13767.55357

 
 Case: 1:17-cv-1946 As of: 08/06/2018 12:45 AM EDT 1 of 4
U.S. District Court Southern District of New York (Foley Square) CIVIL DOCKET FOR CASE #: 1:17−cv−01946−PKC

CLOSED,ECF

The New York Times Company et al v. U.S. Department Of Justice Assigned to: Judge P. Kevin Castel Cause: 05:552 Freedom of Information Act
Plaintiff

Date Filed: 03/16/2017 Date Terminated: 07/30/2018 Jury Demand: None Nature of Suit: 895 Freedom of Information Act Jurisdiction: U.S. Government Defendant

The New York Times Company

represented by Ian MacDougall The New York Times Company 620 Eighth Avenue, 18th Floor New York, NY 10018 (202)−714−3777 Email: ian.macdougall@nytimes.com TERMINATED: 10/06/2017

David Edward McCraw The New York Times Company (10018) 620 Eighth Avenue New York, NY 10018 (212) 556−4031 Fax: (212) 556−1009 Email: mccraw@nytimes.com ATTORNEY TO BE NOTICED

Plaintiff Charlie Savage

represented by Ian MacDougall (See above for address) TERMINATED: 10/06/2017

David Edward McCraw (See above for address) ATTORNEY TO BE NOTICED

V. Defendant U.S. Department Of Justice

represented by Benjamin Henry Torrance U.S. Attorney's Office, SDNY (Chambers Street) 86 Chambers Street New York, NY 10007 212−637−2703 Fax: 212−637−2702 Email: benjamin.torrance@usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
Rebecca Sol Tinio U.S. Attorney's Office, SDNY 86 Chambers Street, 3rd Floor New York, NY 10007 (212) 637−2774 Fax: (212) 637−2702 Email: rebecca.tinio@usdoj.gov LEAD ATTORNEY

Case: 1:17-cv-1946 As of: 08/06/2018 12:45 AM EDT 2 of 4 ATTORNEY TO BE NOTICED

Date Filed 03/16/2017 03/16/2017 03/16/2017
03/16/2017 03/16/2017 03/17/2017
03/17/2017 03/17/2017 03/17/2017 04/04/2017
04/11/2017 04/28/2017 07/12/2017 07/13/2017
09/11/2017 09/12/2017

# Docket Text
1 COMPLAINT against U.S. Department Of Justice. (Filing Fee $ 400.00, Receipt Number 0208−13430763)Document filed by The New York Times Company, Charlie Savage.(McCraw, David) (Entered: 03/16/2017)
2 CIVIL COVER SHEET filed. (McCraw, David) (Entered: 03/16/2017)
3 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Other Affiliate Grupo Finaciero Inbursa, S.A.B. de C.V. for The New York Times Company. Document filed by The New York Times Company.(McCraw, David) (Entered: 03/16/2017)
4 REQUEST FOR ISSUANCE OF SUMMONS as to U.S. Department of Justice, re: 1 Complaint. Document filed by Charlie Savage, The New York Times Company. (McCraw, David) (Entered: 03/16/2017)
5 NOTICE OF APPEARANCE by Ian MacDougall on behalf of Charlie Savage, The New York Times Company. (MacDougall, Ian) (Entered: 03/16/2017)
CASE OPENING INITIAL ASSIGNMENT NOTICE: The above−entitled action is assigned to Judge P. Kevin Castel. Please download and review the Individual Practices of the assigned District Judge, located at http://nysd.uscourts.gov/judges/District. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at http://nysd.uscourts.gov/ecf_filing.php. (pc) (Entered: 03/17/2017)
Magistrate Judge Ronald L. Ellis is so designated. (pc) (Entered: 03/17/2017)
Case Designated ECF. (pc) (Entered: 03/17/2017)
6 ELECTRONIC SUMMONS ISSUED as to U.S. Department Of Justice. (pc) (Entered: 03/17/2017)
7 ORDER INITIAL PRETRIAL CONFERENCE: Initial Conference set for 7/18/2017 at 10:30 AM in Courtroom 11D, 500 Pearl Street, New York, NY 10007 before Judge P. Kevin Castel. (As further set forth in this Order.) (Signed by Judge P. Kevin Castel on 4/4/2017) (cf) (Entered: 04/04/2017)
8 NOTICE OF APPEARANCE by Rebecca Sol Tinio on behalf of U.S. Department Of Justice. (Tinio, Rebecca) (Entered: 04/11/2017)
9 ANSWER to 1 Complaint. Document filed by U.S. Department Of Justice.(Torrance, Benjamin) (Entered: 04/28/2017)
10 LETTER addressed to Judge P. Kevin Castel from Rebecca S. Tinio dated July 12, 2017 re: Case Summary and Request to Endorse Proposed Agreed Deadlines. Document filed by U.S. Department Of Justice.(Tinio, Rebecca) (Entered: 07/12/2017)
11 MEMO ENDORSEMENT on re: 10 Letter filed by U.S. Department Of Justice. ENDORSEMENT: The proposed schedule is approved. The July 18 conference is adjourned to Oct. 6, 2017 at 10:45am. (Initial Conference set for 10/6/2017 at 10:45 AM before Judge P. Kevin Castel.) (Signed by Judge P. Kevin Castel on 7/12/2017) (cf) (Entered: 07/13/2017)
12 LETTER addressed to Judge P. Kevin Castel from Rebecca S. Tinio dated September 11, 2017 re: Status Report and Request for Leave to Submit Further Status Report. Document filed by U.S. Department Of Justice.(Tinio, Rebecca) (Entered: 09/11/2017)
13 MEMO ENDORSEMENT on re: 12 LETTER addressed to Judge P. Kevin Castel from Rebecca S. Tinio dated September 11, 2017 re: Status Report and Request for Leave to Submit Further Status Report. Document filed by U.S. Department Of Justice. ENDORSEMENT: Application granted. So ordered. (Signed by Judge P. Kevin Castel on 9/11/2017) (rjm) (Entered: 09/12/2017)

Case: 1:17-cv-1946 As of: 08/06/2018 12:45 AM EDT 3 of 4

10/02/2017 10/03/2017 10/06/2017
11/15/2017 11/15/2017 01/19/2018 01/22/2018 03/02/2018 03/02/2018 03/13/2018 03/14/2018 03/26/2018 03/27/2018

14 LETTER addressed to Judge P. Kevin Castel from Rebecca S. Tinio dated October 2, 2017 re: Joint Status Report and Request for Leave to Submit Further Status Report. Document filed by U.S. Department Of Justice.(Tinio, Rebecca) (Entered: 10/02/2017)
15 MEMO ENDORSEMENT on re: 14 Letter filed by U.S. Department Of Justice. ENDORSEMENT: Adopted. The parties agreements are adopted as the Order of this Court. Conference is adjourned from October 6 to Nov. 30, 2017 at 11:30 a.m. (Initial Conference set for 11/30/2017 at 11:30 AM before Judge P. Kevin Castel.) (Signed by Judge P. Kevin Castel on 10/3/2017) (cf) (Entered: 10/03/2017)
16 NOTICE OF WITHDRAW AL OF COUNSEL. PLEASE TAKE NOTICE THAT, as of September 18, 2017, Ian MacDougall is no longer with the Legal Department of The New York Times Company and hereby withdraws his appearance as counsel for Plaintiffs The New York Times Company and Charlie Savage in the above−captioned litigation and requests that his name be removed from the Court's and the parties' service lists. David E. McCraw continues to serve as Lead Counsel for Plaintiffs, and all future correspondence and papers in this action should continue to be directed to him. Application for Ian MacDougall to withdraw is granted. So ordered. Attorney Ian MacDougall terminated. (Signed by Judge P. Kevin Castel on 10/6/2017) (rjm) Modified on 11/14/2017 (rjm). (Entered: 10/06/2017)
17 LETTER addressed to Judge P. Kevin Castel from Rebecca S. Tinio dated November 15, 2017 re: Joint Status Report and Request for Leave to Submit Further Status Report. Document filed by U.S. Department Of Justice.(Tinio, Rebecca) (Entered: 11/15/2017)
18 MEMO ENDORSEMENT on re: 17 Letter filed by U.S. Department Of Justice. ENDORSEMENT: Conference Adjourned From: November 30, 2017 To: Jan. 23, 2018 at 10:30 a.m. (Initial Conference set for 1/23/2018 at 10:30 AM before Judge P. Kevin Castel.) (Signed by Judge P. Kevin Castel on 11/15/2017) (cf) (Entered: 11/16/2017)
19 LETTER addressed to Judge P. Kevin Castel from Rebecca S. Tinio dated January 19, 2018 re: Joint Status Report and Request for Leave to Submit Further Status Report. Document filed by U.S. Department Of Justice.(Tinio, Rebecca) (Entered: 01/19/2018)
20 ORDER INITIAL PRETRIAL CONFERENCE: The initial conference scheduled for January 23, 2018 is adjourned to March 20, 2018 at 1:45 p.m. in Courtroom 11D at 500 Pearl Street, New York, NY. Initial Conference set for 3/20/2018 at 01:45 PM in Courtroom 11D, 500 Pearl Street, New York, NY 10007 before Judge P. Kevin Castel. (Signed by Judge P. Kevin Castel on 1/22/2018) (cf) (Entered: 01/22/2018)
21 LETTER addressed to Judge P. Kevin Castel from Rebecca S. Tinio dated March 2, 2018 re: Request for Extension of Time. Document filed by U.S. Department Of Justice.(Tinio, Rebecca) (Entered: 03/02/2018)
22 MEMO ENDORSEMENT on re: 21 Letter filed by U.S. Department Of Justice. ENDORSEMENT: Schedule and proposed actions are adopted as an Order of this Court. (Signed by Judge P. Kevin Castel on 3/2/2018) (cf) (Entered: 03/02/2018)
23 LETTER addressed to Judge P. Kevin Castel from David E. McCraw dated March 13, 2018 re: Request for Adjournment. Document filed by Charlie Savage, The New York Times Company.(McCraw, David) (Entered: 03/13/2018)
24 MEMO ENDORSEMENT on re: 23 Letter filed by The New York Times Company, Charlie Savage. ENDORSEMENT: Conference adjourned from March 20 to April 6, 2018 at 11:00 a.m. (Initial Conference set for 4/6/2018 at 11:00 AM before Judge P. Kevin Castel.) (Signed by Judge P. Kevin Castel on 3/13/2018) (cf) (Entered: 03/14/2018)
NOTICE: The conference originally scheduled for April 6, 2018 is moved to April 2, 2018 at 11:15 a.m. in Courtroom 11D. (Nacanther, Florence) (Entered: 03/26/2018)
25 LETTER addressed to Judge P. Kevin Castel from Rebecca S. Tinio dated March 27, 2018 re: Joint Status Report and Request for Leave to Submit Further Joint Status Report. Document filed by U.S. Department Of Justice.(Tinio, Rebecca) (Entered: 03/27/2018)

Case: 1:17-cv-1946 As of: 08/06/2018 12:45 AM EDT 4 of 4

03/29/2018 05/07/2018 05/09/2018 05/15/2018 05/16/2018 07/30/2018

26 MEMO ENDORSEMENT on re: 25 Letter filed by U.S. Department Of Justice. ENDORSEMENT: The parties agreements are approved and adopted to this Court's Order. Conference adjourned from April 2 to June 1, 2018 at 11:00 a.m. (Initial Conference set for 6/1/2018 at 11:00 AM before Judge P. Kevin Castel.) (Signed by Judge P. Kevin Castel on 3/29/2018) (cf) (Entered: 03/29/2018)
27 LETTER addressed to Judge P. Kevin Castel from Rebecca S. Tinio dated May 7, 2018 re: Status Report and Request for Leave to Submit Further Status Report. Document filed by U.S. Department Of Justice.(Tinio, Rebecca) (Entered: 05/07/2018)
28 MEMO ENDORSEMENT on re: 27 Letter filed by U.S. Department Of Justice. ENDORSEMENT: The agreement of the parties is adopted as an order of the Court. The June 1 conference is adjourned to September 4, 2018 at 2 PM. (Initial Conference set for 9/4/2018 at 02:00 PM before Judge P. Kevin Castel.) (Signed by Judge P. Kevin Castel on 5/9/2018) (cf) (Entered: 05/09/2018)
29 LETTER addressed to Judge P. Kevin Castel from Rebecca S. Tinio dated May 15, 2018 re: Request to Reschedule Conference. Document filed by U.S. Department Of Justice.(Tinio, Rebecca) (Entered: 05/15/2018)
30 MEMO ENDORSEMENT on re: 29 Letter Request to Reschedule Conference, filed by U.S. Department Of Justice. ENDORSEMENT: Conference adjourned from 9/4/2018 to August 28, 2018 at 12p.m. So Ordered., (Initial Conference set for 8/28/2018 at 12:00 PM before Judge P. Kevin Castel.) (Signed by Judge P. Kevin Castel on 5/15/18) (yv) (Entered: 05/17/2018)
31 NOTICE OF VOLUNTARY DISMISSAL Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above−captioned action is voluntarily dismissed, against the defendant(s) All Defendants. Document filed by All Defendants. (Tinio, Rebecca) (Entered: 07/30/2018)