Electronic Frontier Foundation v. Department of Justice

Filing 34

STIPULATION AND ORDER RE 33 TO CONTINUE ALL DATES FOR PARTIES' CROSS MOTIONS FOR SUMMARY JUDGMENT. Signed by Judge Richard Seeborg on 2/7/12. (cl, COURT STAFF) (Filed on 2/7/2012)

*E-Filed 2/7/12*

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Jennifer Lynch (SBN 240701)
[e-mail]
ELECTRONIC FRONTIER FOUNDATION
454 Shotwell Street
San Francisco, CA 94110
Telephone: [phone]
Facsimile: [phone]
David L. Sobel (pro hac vice)
[e-mail]
ELECTRONIC FRONTIER FOUNDATION
1818 N Street, N.W.
Suite 410
Washington, DC 20036
Telephone: [phone] x104
Facsimile: [phone]
Attorneys for Plaintiff
Electronic Frontier Foundation

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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)
ELECTRONIC FRONTIER FOUNDATION, ) Case No. 4:10-cv-04892-RS
)
Plaintiff,
)
) STIPULATION AND [PROPOSED]
vs.
) ORDER TO CONTINUE ALL DATES
) FOR PARTIES’ CROSS MOTIONS
DEPARTMENT OF JUSTICE,
) FOR SUMMARY JUDGMENT BY TWO
) WEEKS
Defendant.
)
) [Civ. L.R. 6-2]
)
) Hon. Richard Seeborg
) Courtroom 3, 17th Floor
)
)
)
)
)

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Case No. CV-10-04892-RS
STIPULATION AND [PROPOSED] ORDER TO CONTINUE ALL DATES FOR PARTIES’
CROSS MOTIONS FOR SUMMARY JUDGMENT

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Pursuant to Fed. R. Civ. P. 6(b)(1) and Civil L.R. 6-2, the parties, by and through

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undersigned counsel, have conferred and hereby stipulate to and respectfully request the Court

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grant an extension to all dates in the briefing schedule previously submitted to and signed by the

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court on January 19, 2012 (Dkt. 32). The new schedule as proposed by the parties is as follows:

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Defendant DOJ and its components DEA, DOJ Criminal
Division and FBI move for summary judgment.

February 23, 2012

Plaintiff files opposition and cross-moves for summary
judgment.

March 22, 2012

Defendant files reply and opposition to Plaintiff’s motion.

April 5, 2012

Plaintiff files reply in support of motion for summary
judgment.

April 19, 2012

Hearing on cross motions.

May 3, 2012

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This requested change will minimally affect the present schedule for the case because it

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proposes continuing all dates, including the hearing date on the parties’ cross motions for summary

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judgment, by just two weeks. In accordance with Civil L.R. 6-2(a), this stipulation is supported by

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the Declaration of Jennifer Lynch, counsel for Plaintiff, filed herewith and a proposed order below.

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The parties have previously stipulated to a briefing schedule (Dkt. 28) and to one

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adjustment to that briefing schedule (Dkt. 32) to accommodate the Defendant and its components’

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schedule. The parties now seek to continue all dates due to previously unforeseen scheduling and

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caseload issues and because Plaintiff’s counsel will be moving immediately prior to the original

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date on which EFF’s Cross Motion would be due (originally calendared for March 9, 2012). The

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parties respectfully request that the schedule above be adopted in place of the schedules previously

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proposed.

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DATED: February 6, 2012

Respectfully submitted,

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/s/ Jennifer Lynch
Jennifer Lynch
ELECTRONIC FRONTIER FOUNDATION
454 Shotwell Street
San Francisco, CA 94110

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Case No. CV-10-04892-RS

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE ALL DATES
FOR PARTIES’ CROSS MOTIONS FOR SUMMARY JUDGMENT

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Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff
ELECTRONIC FRONTIER FOUNDATION

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DECLARATION PURSUANT TO GENERAL ORDER 45

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I, Jennifer Lynch, hereby declare pursuant to General Order 45 that I have obtained

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Defendants’ concurrence in the filing of this document from Nicholas Cartier, Counsel for

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Defendants.

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Executed on February 6, 2012, in San Francisco, California.

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/s/ Jennifer Lynch
Jennifer Lynch

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
2/7/12
Dated: ______________

The Hon. RICHARD SEEBORG
United States District Judge

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Case No. CV-10-04892-RS

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE ALL DATES
FOR PARTIES’ CROSS MOTIONS FOR SUMMARY JUDGMENT