FOIA action, the parties anticipate that any legal issues will be resolved through cross-motions for summary judgment without discovery. See, e.g., Wood y. FBI, 432 F.3d 78, 85 (2d Cir. 2005); Carney v. U.S. Dep'r of Justice, 19 F.3d 807, 812-13 (2d Cir. 1994). Accordingly, the parties respectfully request