Case 1:17-cv-03960-JMF Document 15 Filed 06/21/17 Page 1 of 3 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK CHARLES SEIFE, Plaintiff, v. Case No. 1:17-cv-3960 FOOD AND DRUG ADMINISTRATION and DEPARTMENT OF HEALTH AND HUMAN SERVICES, Defendants. NOTICE OF MOTION FOR PARTIAL SUMMARY JUDGMENT PLEASE TAKE NOTICE that upon the annexed memorandum of law; supporting declarations of Charles Seife and Cortelyou Kenney and the exhibits appended thereto; Local Rule 56.1 statement of undisputed material facts; and all prior pleading and proceedings herein, Plaintiff Charles Seife moves this Court for partial summary judgment on Count I of his Complaint. Specifically, Seife seeks an order (1) requiring defendants to provide a full written response to his Freedom of Information Act request within ten days, and (2) setting a status conference within twenty days of this Court’s order to establish a schedule for the expedited release of the requested information on a rolling basis, as well as such other and further relief as the Court deems just and proper. Cortelyou Kenney Margaret McCarthy Mark Dore, Law Student Intern David Stanton, Law Student Intern Darius Fullmer, Law Student Intern Media Freedom & Information Access Clinic Abrams Institute for Freedom of Expression Yale Law School Case 1:17-cv-03960-JMF Document 15 Filed 06/21/17 Page 2 of 3 P.O. Box 208215 New Haven, CT 06520 Tel: (203) 432-9387 Fax: (203) 432-3034
[email protected] [email protected] David A. Schulz 321 West 44th Street, Suite 1000 New York, NY 10036 Tel: (212) 850-6100 Fax: (212) 850-6299
[email protected] Dated: New York, NY June 21, 2017 Counsel for Plaintiff Case 1:17-cv-03960-JMF Document 15 Filed 06/21/17 Page 3 of 3 CERTIFICATE OF SERVICE I certify that on June 21, 2017, this Motion was filed with the Clerk of the Court using the Court’s CM/ECF docketing system, which will mail a copy of all counsel of record capable of receiving electronic pleadings.