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01/17/2019 Plaintiff Cross Motion for Summary Judgment

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

CROSS MOTION FOR SUMMARY JUDGEMENT

Plaintiff hereby moves for summary judgement pursuant to Federal Rule of Civil Procedure 56 and Local Rule 7(j)(2) on the grounds that Defendants have not satisfied all of their obligations with respect to Plaintiff’s FOIA requests.

            Plaintiff demonstrates NARA’s failure to produce all responsive records to which Plaintiff is entitled.

            In support of the cross motion, Plaintiff respectfully refers the Court to the accompanying Statement Of Material Facts Not In Dispute And Response To Defendant’s Statement Of Facts Not In Dispute and Memorandum Of Law In Support Of Plaintiff’s Cross Motion For Summary Judgment In Opposition To Defendants’ Motion For Summary Judgement with exhibits attached thereto.

Respectfully submitted,

                                                                        ____________________________

                                                                        Grant F. Smith, PRO SE

IRmep
P.O. Box 32041
Washington, D.C. 20007

For process service:

Grant F. Smith c/o IRmep
1100 H St. NW Suite 840
Washington, D.C. 20005

                                                                        (202) 342-7325

Dated: January 17, 2018