Court filing
Joint letter on adequacy-of-search dispute — PHMPT v. FDA
Filed September 2, 2024 in Public Health and Medical Professionals for Transparency v. Food and Drug Administration; one of 30 filings from this case.
Record facts
| Court | U.S. District Court for the Northern District of Texas |
|---|---|
| Filed | 2024-09-02 |
U.S. District Court for the Northern District of Texas · No. 4:21-cv-01058-P · Doc. 83 · 2024-09-02 · Docket on CourtListener
Full text
VIA ECF September 2, 2024 Honorable Mark T. Pittman 501 West 10th Street, Room 401 Fort Worth, Texas 76102-3673 Re: Public Health & Med. Pros. For Transparency v. Food and Drug Administration US District Court for the Northern District of Texas; Case No. 4:21-cv-01058-P Joint letter Dear Judge Pittman: We write on behalf of the parties in the above-referenced action to jointly update the Court following the parties’ recent discussions. The parties agree there is a contested issue concerning the adequacy of the search which they have been unable to resolve despite conferring multiple times regarding same. Therefore, we agree that briefing this adequacy of search issue now is appropriate and propose the briefing schedule below. After the Court has ruled on that issue, and processing is completed for any additional records, as applicable, the parties would like to then meet and confer about redactions in dispute, if any, and revert only if necessary to the Court. We therefore propose the following briefing schedule to address the adequacy of the agency’s search: • Defendant’s motion for summary judgment due: October 17 • Plaintiff’s cross-motion and response due: November 21 • Defendant’s reply and response due: December 19 • Plaintiff’s reply due: January 16 If there are any other issues the Court would like the parties to address prior to the scheduled status conference, or if the Court intends to cancel the conference in light of the foregoing, the parties welcome addressing those issues and respectfully request advanced notice of same. Thank you for your consideration. Very truly yours, /s/ Andrew F. Freidah /s/Elizabeth A. Brehm Andrew F. Freidah Elizabeth A. Brehm Trial Attorney 745 Fifth Avenue, Suite 500 United States Department of Justice New York, NY 10151 Civil Division (888) 747-4529 1100 L Street NW ebrehm@sirillp.com Washington, D.C. 20005 (202) 305-0879 Attorney for Plaintiff andrew.f.freidah@usdoj.gov Attorney for Defendant Case 4:21-cv-01058-P Document 83 Filed 09/02/24 Page 1 of 1 PageID 2327
File and source
- File
- gov.uscourts.txnd.353278.83.0.pdf
- Size
- 169,995 bytes
- SHA-256
- 83a29f55fa1c83741e041e4ef8e5e260e06197636d23ed4c4fe9686758251288
- Original
- archive.org