IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

AMERICAN HISTORICAL ASSOCIATION, et al.,
Plaintiffs,

v.

THE NATIONAL ARCHIVES AND RECORDS ADMINISTRATION, et al.,
Defendants.

No. 1:01CV02447 (CKK)

PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT

Plaintiffs, through their undersigned counsel, hereby respectfully move for an order granting them summary judgment and (1) declaring that the defendants may not implement Executive Order 13,233, (2) permanently enjoining them from doing so, and (3) requiring them to open Reagan presidential records and Bush vice presidential records without regard to the terms of the Executive Order 13,233. The grounds for this Motion are set forth in full in the accompanying Memorandum of Points and Authorities.

Respectfully submitted,

Scott L. Nelson, D.C. Bar No. 413548
David C. Vladeck, D.C. Bar No. 945063
Michael Tankersley, D.C. Bar No. 411978
Public Citizen Litigation Group
1600 20th Street, N.W.
Washington, D.C. 20009
(202) 588-1000

Attorneys for Plaintiffs

February 8, 2002