Electronic Frontier Foundation v. Department of Defense et al

Filing 48

ORDER adjusting briefing schedule (tf, COURT STAFF) (Filed on 3/1/2011)

Electronic Frontier Foundation v. Department of Defense et al

Doc. 48

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Jennifer Lynch (SBN 240701) [e-mail] Marcia Hoffmann (SBN 250087) [e-mail] ELECTRONIC FRONTIER FOUNDATION 454 Shotwell Street San Francisco, CA 94110 Telephone: [phone] Facsimile: [phone] Jason M. Schultz (SBN 212600) [e-mail] SAMUELSON LAW, TECHNOLOGY & PUBLIC POLICY CLINIC UC Berkeley School of Law 396 Simon Hall Berkeley, CA 94720-7200 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff Electronic Frontier Foundation IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) ELECTRONIC FRONTIER FOUNDATION, ) Case No. 3:09-CV-05640-SI ) Plaintiff, ) )STIPULATION AND [PROPOSED] vs. )ORDER FOR BRIEFING SCHEDULE ) DEPARTMENT OF DEFENSE, ET AL., ) Judge: Hon. Susan Illston ) Date: February 25, 2011 Defendants. ) Time: 2:30 p.m. ) Place: Courtroom 10, 19th Floor ) ) )

Case No. 3:09-CV-05640-SI STIPULATION AND [PROPOSED] O RDER FOR BRIEFING SCHEDULE

Dockets.Justia.com

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This matter came on for a status hearing before the Court on February 25, 2011. In preparation for the status hearing, the parties have conferred and agreed to a procedure intended to streamline the resolution of the remaining issues in this lawsuit. In furtherance of this objective, and with the goal of making the most efficient use of scarce judicial resources, the parties have agreed to the following deadlines in this case. The parties jointly request that the Court adopt the parties' proposed schedule.

Defendants DHS/ICE complete search and production of all documents. Defendants DHS/ICE provide Plaintiff with a draft Vaughn index and a description of their searches. Plaintiff will inform DHS/ICE of the documents and redactions on which it would like to proceed to summary judgment. Defendants Secret Service, FBI, Criminal Division, DHS, and ICE move for summary judgment and file Vaughn indexes with the Court. Plaintiff files opposition and cross-moves for summary judgment. Defendants file reply and opposition to Plaintiff's motion. Plaintiff files reply in support of motion for summary judgment. Oral argument.

May 25, 2011

July 1, 2011

August 8, 2011

September 23, 2011 October 21, 2011 November 4, 2011 November 18, 2011 December 9, 2011

Case No. 3:09-CV-05640-SI -2STIPULATION AND [PROPOSED] O RDER FOR BRIEFING SCHEDULE

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Case No. 3:09-CV-05640-SI -3STIPULATION AND [PROPOSED] O RDER FOR BRIEFING SCHEDULE

DATED: February 28, 2011

Respectfully submitted,

/s/ Jennifer Lynch ELECTRONIC FRONTIER FOUNDATION Jennifer Lynch, Esq. Marcia Hofmann, Esq. 454 Shotwell Street San Francisco, CA 94110 Telephone: [phone] Facsimile: [phone] SAMUELSON LAW, TECHNOLOGY AND PUBLIC POLICY CLINIC Jason M. Schultz U.C. Berkeley School of Law 396 Simon Hall Berkeley, CA 94720-7200 Telephone: [phone] Facsimile: [phone]

TONY WEST Assistant Attorney General JOHN TYLER Assistant Branch Director /s/ Kimberly Herb Kimberly L. Herb Trial Attorney United Stated Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Ave. NW Washington, DC 20530 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Attorneys for Defendants

Attorneys for Plaintiff GENERAL ORDER NO. 45(X) CERTIFICATION I attest that I have obtained Kimberly Herb's concurrence in the filing of this document. /s/ Jennifer Lynch Jennifer Lynch PURSUANT TO STIPULATION, IT IS SO ORDERED. 2/28/11 Dated: ________________

___________________________ Hon. Susan Ilston United States District Judge