Log Cabin Republicans v. United States of America et al

Filing 134

STIPULATION for Extension of Time to Amend filed by Defendants Donald H Rumsfeld, United States of America. (Attachments: #1 Proposed Order)(Freeborne, Paul)

Log Cabin Republicans v. United States of America et al

Doc. 134

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

TONY WEST Assistant Attorney General ANDRÉ BIROTTE, Jr. United States Attorney VINCENT M. GARVEY PAUL G. FREEBORNE W. SCOTT SIMPSON JOSHUA E. GARDNER RYAN B. PARKER U.S. Department of Justice Civil Division Federal Programs Branch P.O. Box 883 Washington, D.C. 20044 Telephone: [phone] Facsimile: [phone] E-mail: paul.freeborne@ usdoj.gov Attorneys for Defendants United States of America and Secretary of Defense UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA EASTERN DIVISION LOG CABIN REPUBLICANS, ) ) ) ) Plaintiff, ) ) v. ) ) UNITED STATES OF AMERICA AND ) ROBERT M. GATES, Secretary of ) Defense, in his official capacity, ) ) Defendants. ) ) ) ) Case No. CV 04-8425 VAP (Ex) STIPULATION RE: STAY OF OBLIGATION AND EXTENSION OF TIME TO COMPLY WITH MAGISTRATE JUDGE'S MARCH 16, 2010 DISCOVERY RULING Complaint filed: April 28, 2006 Trial date: June 14, 2010

WHEREAS, the Magistrate Judge ruled on March 16, 2010 that, "[w]ithin (10) days of this Order, Defendant United States shall unqualifiedly admit or deny Requests for Admissions Nos. 3, 4, 5, and 81-105, the Court having overruled all objections thereto," WHEREAS Defendants are filing a Motion for Review of the Magistrate Judge's Discovery Ruling pursuant to Local Rule 72-2.1 insofar as it concerns
Stipulation re: Extension of Time for Defendants to Answer the First Amended Complaint

Dockets.Justia.com

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Requests for Admission Nos. 3, 4, and 5, WHEREAS the filing of said Motion for Review of the Magistrate Judge's Discovery Ruling does not automatically stay Defendants' obligation to comply with the Magistrate Judge's Ruling; and WHEREAS the parties have conferred through counsel in accordance with Local rule 7-3, The parties HEREBY STIPULATE AND AGREE as follows: Defendants' obligation to comply with the Magistrate Judge's Discovery Ruling regarding responses to Requests for Admission Nos. 3, 4, and 5 is stayed pending the Court's ruling on Defendants' Motion for Review of the Magistrate Judge's Discovery Ruling; The parties agree that Defendants will file their motion on Friday, March 26, 2010; Plaintiff will oppose Defendants' Motion on Tuesday, March 30, 2010, and Defendants will file a reply in support of the motion on Thursday, April 1, 2010. The parties also agree that the matter be deemed submitted for decision upon that completion of that briefing, unless the Court determines that a hearing is necessary; Defendants will admit Request for Admission Nos. 81, 82, and 84-104; Defendants are unable to admit or deny Request for Admission No. 83 after reasonable inquiry, and Plaintiff will withdraw its objection to that response; Defendant will admit Request for Admission No. 105 with respect to 23 countries.

-2-

Stipulation re: Extension of Time for Defendants to Answer the First Amended Complaint

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

/s/ Paul G. Freeborne Paul G. Freeborne U.S. Department of Justice Civil Division Federal Programs Branch P.O. Box 883 Washington, D.C. 20044 Telephone: [phone] Facsimile: [phone] Attorney for Defendants Dated: March 26 2010

_/s/ Dan Woods Dan Woods White & Case, LLP 633 West Fifth Street Suite 1900 Los Angeles, CA 90071 Telephone: [phone] Facsimile: [phone] Attorney for Plaintiff

-3-

Stipulation re: Extension of Time for Defendants to Answer the First Amended Complaint