Log Cabin Republicans v. United States of America et al

Filing 118

EX PARTE APPLICATION for Order for Compelling Defendants to Comply with Plaintiff's F.R.C.P. Notice of Deposition of USA and Gates filed by Plaintiff Log Cabin Republicans. (Attachments: #1 Proposed Order, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F)(Hunnius, Patrick)

Log Cabin Republicans v. United States of America et al

Doc. 118 Att. 7

Exhibit F

Dockets.Justia.com

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Hagan, Patrick
From: Sent: To: Hunnius, Patrick Friday, March 05, 2010 3:39 PM Miller, Earle; Hagan, Patrick; Kahn, Aaron; Feldman, Rachel; Fujiu, Lauren; Hunnius, Patrick; Scott, Melanie C.; Woods, Dan

Subject: FW: Log Cabin Republicans: Proposed Ex Parte Applications

Patrick O. Hunnius
Telephone: + 213-620-7714 Mobile: + 818-205-4976

From: Freeborne, Paul (CIV) [mailto:[e-mail]] Sent: Friday, March 05, 2010 3:26 PM To: Hunnius, Patrick; Parker, Ryan (CIV); Woods, Dan Cc: Garvey, Vincent (CIV); Hunt, Jody (CIV); Simpson, Scott (CIV) Subject: Re: Log Cabin Republicans: Proposed Ex Parte Applications Patrick, As you know, we agreed during the "meet and confer" on February 9th that plaintiff would initiate the stipulation process. You clearly understood that to be the case (i.e, we agreed to proceed through stipulation and crossmotion) as evidenced by the way you have proceeded (until now). Paul

From: Hunnius, Patrick <[e-mail]> To: Parker, Ryan (CIV); Woods, Dan <[e-mail]> Cc: Freeborne, Paul (CIV); Garvey, Vincent (CIV); Hunt, Jody (CIV); Simpson, Scott (CIV) Sent: Fri Mar 05 17:29:23 2010 Subject: RE: Log Cabin Republicans: Proposed Ex Parte Applications

Ryan, One of the exhibits you attached is a letter I sent Mr. Freeborne on February 11, in which Log Cabin Republicans "propose[d] that the parties agree to brief the cross-motions [regarding the 30(b)(6) deposition] on an expedited basis." (Emphasis added) Furthermore, the letter proposed a schedule and requested that the government "let me know by Wednesday if this schedule is agreeable." I never received any response to the proposal and no such response is attached to your email (below). In your letter to me dated today, however, you contend that the government "agreed" to the briefing schedule proposed by Log Cabin Republicans. See, e.g. (February 22nd was "previously agreed" to as the date by which Plaintiff would send its portion of a Joint Stipulation; February 22nd was the "agreed upon date" for Plaintiff's serving its portion of a

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Joint Stipulation.) We have received no written or oral communication from the government in which the government told us that it agreed to the proposal. Please let me know immediately when and in what form you contend the government indicated it agreed to the briefing schedule proposed in my February 11 letter. Patrick O. Hunnius
Telephone: + 213-620-7714 Mobile: + 818-205-4976

From: Parker, Ryan (CIV) [mailto:[e-mail]] Sent: Friday, March 05, 2010 11:20 AM To: Hunnius, Patrick; Woods, Dan Cc: Freeborne, Paul (CIV); Garvey, Vincent (CIV); Hunt, Jody (CIV); Simpson, Scott (CIV) Subject: Log Cabin Republicans: Proposed Ex Parte Applications

Patrick, Please find attached a letter, with attachments, setting forth the Government's opposition to your proposal to file ex parte applications. Best, Ryan B. Parker Trial Attorney U.S. Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Ave. NW Washington, DC 20001 tel [phone] fax [phone] [e-mail]

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3/5/2010