Al-Haramain Islamic Foundation, Inc. et al v. Bush et al

Filing 88

STIPULATION AND ORDER approving 87 Stipulation, filed by Office of Foreign Assets Control, Robert S. Mueller, III, Barack Obama, Keith B. Alexander, Adam J Szubin, Federal Bureau of Investigation, National Security Agency. Signed by Judge Vaughn R Walker on 5/1/2009. (vrwlc3, COURT STAFF) (Filed on 5/1/2009)

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MICHAEL F. HERTZ Acting Assistant Attorney General DOUGLAS N. LETTER Terrorism Litigation Counsel JOSEPH H. HUNT Director, Federal Programs Branch VINCENT M. GARVEY Deputy Branch Director ANTHONY J. COPPOLINO Special Litigation Counsel ALEXANDER K. HAAS Trial Attorney U.S. Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Avenue, NW, Rm. 6102 Washington, D.C. 20001 Phone: [phone]--Fax: [phone] Attorneys for the Government Defendants UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION IN RE NATIONAL SECURITY AGENCY TELECOMMUNICATIONS RECORDS LITIGATION This Document Solely Relates To: Al-Haramain Islamic Foundation et al. v. Obama, et al. (07-CV-109-VRW) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. M:06-CV-01791-VRW STIPULATION TO EXTEND RESPONSE DATE IN ORDER OF APRIL 17, 2009 [DKT. 84] AND PROPOSED ORDER [Civil L.R. 6-1(b); 6-2; 7-12] Courtroom: Judge: 6, 17th Floor Hon. Vaughn R. Walker

Pursuant to Local Rule 6.1(b), the parties, through their undersigned counsel, hereby stipulate to an extension of the response date set forth in the Court's Order of April 17, 2009 (Dkt. 84 in 07-cv-109-VRW) from May 8, 2009 to May 15, 2009. RECITALS 1. On April 17, 2009, the Court issued an order directing the parties to meet and

confer regarding the entry of an appropriate protective order in this action concerning classified
Stipulation to Extend Response Date in Order of April 17, 2009 [Dkt. 84] Al-Haramain v. Obama (07-cv-109-VRW) (MDL06-cv-1791-VRW)

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information and to either submit a stipulated order by May 8, 2009, or, if the parties are unable to agree on all terms, to jointly submit a document containing all agreed terms together with a document setting forth the terms about which they are unable to reach agreement and the respective positions of the parties with regard to each such term. See Order, April 17, 2009 (Dkt. 84 in 07-cv-109-VRW). 2. Plaintiffs forwarded their proposed draft protective order to the Government

Defendants on April 24, 2009. 3. The Government Defendants require additional time to complete internal

deliberations on its position in response to the Court's Order, confer with the plaintiffs regarding the Government's position, and prepare the Government's response under the Order. 4. In addition, the undersigned counsel for the Government (Mr. Coppolino) is

currently scheduled to be before the Court in San Francisco on May 7, 2009, for a hearing on a separate matter in this MDL proceeding (the Government's motion for summary judgement in actions concerning various state government investigations, see Dkt. 536 (Government's motion) and Dkt. 574 (setting hearing for May 7, 2009) in MDL 06-cv-1791-VRW). 5. No prior modifications of the response date in the Court's April 17 Order have

been sought or entered. L.R. 6-2(a)(2). 6. The requested time modification would have no other impact on the schedule of

this case. L.R. 6-2(a)(3). STIPULATION Pursuant to L.R. 6.1(b), the parties, through their undersigned counsel, hereby stipulate and agree to a one-week extension of the response date set by the Court in its April 17 Order from May 8, 2009 to May 15, 2009. DATED: April 30, 2009 Respectfully Submitted, MICHAEL F. HERTZ Acting Assistant Attorney General DOUGLAS N. LETTER Terrorism Litigation Counsel
Stipulation to Extend Response Date in Order of April 17, 2009 [Dkt. 84] Al-Haramain v. Obama (07-cv-109-VRW) (MDL06-cv-1791-VRW)

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JOSEPH H. HUNT Director, Federal Programs Branch VINCENT M. GARVEY Deputy Branch Director ANTHONY J. COPPOLINO Special Litigation Counsel ALEXANDER K. HAAS Trial Attorney U.S. Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Avenue, NW, Rm. 6102 Washington, D.C. 20001 Phone: [phone]--Fax: [phone] By: s/ Anthony J. Coppolino Anthony J. Coppolino Attorneys for the Government Defendants

Stipulation to Extend Response Date in Order of April 17, 2009 [Dkt. 84] Al-Haramain v. Obama (07-cv-109-VRW) (MDL06-cv-1791-VRW)

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[PROPOSED] ORDER Pursuant to the foregoing Stipulation, and good cause appearing, the Court hereby orders that the response date set forth in the Court's Order of April 17, 2009 [Dkt. 84] shall be and hereby is extended to May 15, 2009. PURSUANT TO STIPULATION, IT IS SO ORDERED:

________________________________ Hon. Vaughn R. Walker United States District Chief Judge

Stipulation to Extend Response Date in Order of April 17, 2009 [Dkt. 84] Al-Haramain v. Obama (07-cv-109-VRW) (MDL06-cv-1791-VRW)

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