1Plaintiff’s suit arises under the Freedom of Information Act (“FOIA”), and relates to two FOIA requests submitted to Defendant in January 2026 and February 2026. Plaintiff filed its suit in March 2026 (ECF No. 1) and Defendant filed its Answer in April 2026 (ECF No. 6). In a Minute Order dated April 30, 2026, this Court has ordered the parties to “confer and file a joint proposed schedule for briefing or disclosure by May 14, 2026.”
2The parties have conferred via electronic mail and jointly provide the following report. With respect to FOIA request 2026-HQFO-01584, Defendant reports that preliminary searches are complete and located approximately 252 pages of potentially responsive records for review; Defendant expects to make a production of responsive, non-exempt records by June 15, 2026. With respect to FOIA request 2026-ICFO-17498, Defendant reports that preliminary searches are in progress. Defendant notes that as a result of the partial lapse in appropriations that
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began in February 2026, DHS and its components are facing a backlog of FOIA requests that has impacted their ability to promptly process new requests such as these.
3The parties respectfully submit that it would be premature to establish a briefing schedule at this time. Once Defendant makes its expected productions and final determinations, the parties will meet and confer to narrow or eliminate issues that might otherwise be subject to motion practice.
4The parties propose to submit a joint status report in ninety days, and every ninety days thereafter, to apprise the Court of developments in this litigation. Dated: May 14, 2026 /s/ Kelly Brian McClanahan Kelly Brian McClanahan
NATIONAL SECURITY COUNSELORS
1451 Rockville Pike, Suite 250 Rockville, MD 20852 501-301-4672 Email: [email protected] Counsel for Plaintiff
Respectfully submitted, JEANINE FERRIS PIRRO United States Attorney By: /s/ Andrew J. Vaden ANDREW J. VADEN, D.C. Bar #1044860 Assistant United States Attorney 601 D Street, NW Washington, DC 20530 (202) 252-2437 Attorneys for the United States of America
