Rosenfeld v. Federal Bureau of Investigation et al

Filing 58

STIPULATION AND ORDER extending deadline to and including 2/5/2009 to file a joint case management conference statement; Signed by Judge Marilyn Hall Patel on 2/4/2009. (awb, COURT-STAFF) (Filed on 2/5/2009)

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JOSEPH P. RUSSONIELLO (CSBN 44332) United States Attorney JOANN M. SWANSON (CSBN 88143) Chief, Civil Division ELLEN M. FITZGERALD (NY 2408805) Assistant United States Attorney 450 Golden Gate Avenue, 9th Floor San Francisco, California 94102-3495 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Attorneys for Defendants UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION SETH ROSENFELD, Plaintiff, v. UNITED STATES DEPARTMENT OF JUSTICE, and UNITED STATES FEDERAL BUREAU OF INVESTIGATION, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) No. C 07-3240 MHP Related Cases: No. C 85-1709 MHP; No. C 85-2247 MHP; No. C 90-3576 MHP STIPULATION AND JOINT MOTION TO EXTEND DEADLINE FOR FILING OF JOINT CASE MANAGEMENT CONFERENCE STATEMENT; [PROPOSED] ORDER

Subject to the Court's approval, the parties, through their undersigned counsel, hereby agree and stipulate that the deadline for submission of their joint case management conference statement will be extended from February 2, 2009 to February 5, 2009. The parties are scheduled to appear for a case management conference on Monday, February 9, 2009. Plaintiff intends to include in the joint case management conference statement a detailed analysis containing (1) his suggested course of action; (2) his objections to defendants' evidence submitted in response to the Court's order, dated August 22, 2008; (3) his statement regarding defendants' alleged failure to adequately search for responsive records; and (4) his report regarding defendants' compliance with agreed-upon productions. Plaintiff has not yet provided defendants with his portion of the joint statement, and, as a result, defendants have not

STIPULATION AND JOINT MOTION TO EXTEND DEADLINE FOR SUBMISSION OF JOINT CASE MANAGEMENT CONFERENCE STATEMENT; [PROPOSED] ORDER C 07-03240 MHP

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yet had an opportunity to review plaintiff's analysis. The brief extension will give defendant time to prepare a response to plaintiff's proposals and will thus ensure that the joint case management conference statement provides the Court with a complete picture of the parties' respective positions. IT IS SO STIPULATED. Respectfully submitted, Dated: February 2, 2009 By: FIRST AMENDMENT PROJECT /s/ DAVID GREENE Attorneys for Plaintiff JOSEPH P. RUSSONIELLO United States Attorney By: /s/ ELLEN M. FITZGERALD Assistant United States Attorney Attorneys for Defendants

Dated: February 2, 2009

APPROVED AND SO ORDERED. The deadline for submission of the parties' joint case management conference statement is hereby extended from February 2, 2009 to February 5, 2009.

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STIPULATION AND JOINT MOTION TO EXTEND DEADLINE FOR SUBMISSION OF JOINT CASE MANAGEMENT CONFERENCE STATEMENT; [PROPOSED] ORDER 2 C 07-03240 MHP

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HON. IS SO ORD MARILYN HALL PATEL UnIted States District Judge iT

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