IT IS SO ORDERED,

TUDGE THOMAS A. FLANNERY ae
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

Dued_8- BO- 9


UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

DEMOCRATIC CONGRESSIONAL
CAMPAIGN COMMITTEE, INC.,

Plaintiff,
v.

FEDERAL ELRGHIGN COD, CIVIL ACTION NO. 1:96CV00764-TAF

Defendant. FILED

AUG 30 1996
RULE 206 JOINT MEET AND CONFER REPORT

NANCY MAYER.WHITTINGTON,
AND PROPOSED SCHEDULING ORDER USOC! COURT CLERK

Pursuant to Local Rule 206, on August 27, 1996, counsel for both parties met and

conferred by telephone, Pursuant to Local Rule 206(d), counsel jointly report the following:

i Counsel jointly agree that this matter does not involve contested facts and
therefore can be disposed af an cross-motions for summary judgment. Thus, counsel jointly
agree that this case should be placed on a fast track.

as Counsel jointly agree that there will be no additional parties joined to this

matter nor pleadings amended.

2; Counsel jointly agree that this matter should not be assigned to a Magistrate
Judge.

4 Counsel jointly agree that they have becn unable to settle the case.

S;,

Since this matter involves a question of law related to the propriety of the

Federal Election Commission’s (the “Commission”) actions with respect to an administrative

[4031 -0001/D.4962400022 4-30 776- EB iy Ve Aw



igoos
Hosa RS 11:24 202 273 4791 T.A. FLANNERY

complaint filed by the Plaintiff, counsel agree that this case would not benefit from any form
of alternative dispute resolution procedures.

6. Counsel jointly agree that this matter can be resolved by cross-motion for
summary judgment.

4 Counsel jointly agree that the initial disclosure requirements of Rule 26(A)1)
of the Federal Rules of Civil Procedure are not applicable in this matter and should be
dispensed with.

8. Tt is anticipated that the extent of discovery in this matter will be the
Commission providing Plaintiff with a chronology of activity that the Commission has
undertaken with respect to MUR 4128. Because the information contained in such a
chronology must be kept confidential by law, the parties jointly agree that a protective order is
appropriate. Furthermore, counsel Jointly agree that a stipulated protective order should be
filed with the Court no later than September 6, 1996, Assuming that the order is granted by
the Court, the parties jointly agree that the Commission will provide Plaintiff's counsel with

the chronology no later than two (2) days of notice of the Court’s approval of the protective

order.

9. Not applicable,

10. Not applicable.

11. Not applicable.

12. The parties jointly agree that at this time it does not appear that a pretrial
conference will be necessary.

13. Not applicable.

In addition, counsel jointly agree to the following briefing schedule, subject to Court
approval:


Plaintiff s Motion for Summary Judgment 2 weeks after receipt of chronology

Defendant's Opposition and Cross-Motion 30 days after filing of Plaintiff's Motion for

for Summary Judgment

Plaintiff's Reply

Defendant's Reply

Dated: August 29, 1996

Summary Judgment

10 days after filing of Defendant’s Opposition
and Cross-Motion

10 days after Plaintiff's Reply

Respectfully submitted,

ZAEEAE

Robert F, Bauer (DC Bar 938902)
Marc E. Elias (DC Bar 442007)
PERKINS COIE

607 Fourteenth Street, N.W.
Washington, D.C. 20005

(202) 628-6600

Counsel for Plaintiff
Democratic Congressional Campaign Committee

Lee MMs p44)

Lawrence M. Noble

FEDERAL ELECTION RATS
999 E Street, N.W. - Sixth Floor
Washington, D.C, 20463

(202) 219-3690

Counsel for Defendant
Federal Election Commission