Jewel et al v. National Security Agency et al

Filing 39

Declaration of Cindy A. Cohn in Support of 38 MOTION for Leave to File Supplemental Brief on the Scope of FISA Act Preemption filed byTash Hepting, Gregory Hicks, Carolyn Jewel, Erik Knutzen, Joice Walton. (Related document(s) 38 ) (Blizzard, Paula) (Filed on 8/3/2009)

Jewel et al v. National Security Agency et al

Doc. 39

Case3:08-cv-04373-VRW Document39

Filed08/03/09 Page1 of 2

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ELECTRONIC FRONTIER FOUNDATION CINDY COHN (SBN 145997) [e-mail] LEE TIEN (SBN 148216) KURT OPSAHL (SBN 191303) KEVIN S. BANKSTON (SBN 217026) JAMES S. TYRE (SBN 083117) 454 Shotwell Street San Francisco, California 94110 Telephone: [phone]; Facsimile: [phone] KEKER & VAN NEST, LLP RACHAEL E. MENY (SBN 178514) [e-mail] PAULA L. BLIZZARD (SBN 207920) [e-mail] MICHAEL S. KWUN (SBN 198945) [e-mail] AUDREY WALTON-HADLOCK (SBN 250574) [e-mail] 710 Sansome Street San Francisco, California 94111-1704 Telephone: [phone]; Facsimile: [phone] LAW OFFICE OF RICHARD R. WIEBE RICHARD R. WIEBE (SBN 121156) [e-mail] 425 California Street, Suite 2025 San Francisco, California 94104 Telephone: [phone]; Facsimile: [phone] THE MOORE LAW GROUP THOMAS E. MOORE III (SBN 115107) [e-mail] 228 Hamilton Avenue, 3rd Floor Palo Alto, California 94301 Telephone: [phone]; Facsimile: [phone] Attorneys for Plaintiffs UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA CAROLYN JEWEL, TASH HEPTING, GREGORY HICKS, ERIK KNUTZEN and JOICE WALTON, on behalf of themselves and all other similarly situated, Plaintiffs, v. NATIONAL SECURITY AGENCY, et al., Defendants. Case No. C-08-4373-VRW CLASS ACTION DECLARATION OF CINDY A. COHN IN SUPPORT OF ADMINISTRATIVE MOTION FOR LEAVE TO FILE SUPPLEMENTAL BRIEF ON THE SCOPE OF FISA ACT PREEMPTION Local Rule 7-11 Judge: Vaughn R. Walker Date Comp. Filed: September 18, 2008

446493.01

DECLARATION OF CINDY A. COHN IN SUPPORT OF ADMINISTRATIVE MOTION FOR LEAVE TO FILE SUPPLEMENTAL BRIEF ON THE SCOPE OF FISA ACT PREEMPTION CASE NO. C-08-4373-VRW Dockets.Justia.com

Case3:08-cv-04373-VRW Document39

Filed08/03/09 Page2 of 2

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I, CINDY A. COHN, hereby declare, 1. I am an attorney of record for Plaintiffs in this action and a member of good

Standing of the California State Bar, and am admitted to practice before this Court. I have personal knowledge of the matters stated in this declaration. If called upon to do so, I am competent to testify to all matters set forth herein. 2. I left a message for defense counsel Mr. Coppolino on July 30, informing him of

this motion and request and offering that plaintiffs would agree that the government could have 10 court days to respond with a brief of comparable length. 3. Mr. Coppolino returned my call later that day and indicated that he would prefer

to reserve the government's position until he sees the motion and brief. He also indicated that given his current schedule, if the Court was going to grant our motion, he would seek at least thirty days to respond to the brief from the date that the motion was granted. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed in San Francisco, California, on August 3, 2009.

By:

/s/ Cindy A. Cohn CINDY A. COHN

1
446493.01

DECLARATION OF CINDY A. COHN IN SUPPORT OF ADMINISTRATIVE MOTION FOR LEAVE TO FILE SUPPLEMENTAL BRIEF ON THE SCOPE OF FISA ACT PREEMPTION CASE NO. C-08-4373-VRW