Electronic Frontier Foundation v. Department of Justice
Filing
47
STIPULATION AND ORDER RE 45 TO CONTINUE ALL REMAINING DATES IN BRIEFING SCHEDULE FOR PARTIES' CROSS-MOTIONS FOR SUMMARY JUDGMENT BY TWO WEEKS. Signed by Judge Richard Seeborg on 4/10/12. (cl, COURT STAFF) (Filed on 4/10/2012)
1
2
3
4
5
6
7
8
9
TONY WEST
Assistant Attorney General
MELINDA HAAG
United States Attorney
ELIZABETH J. SHAPIRO
Deputy Branch Director, Federal Programs Branch
Civil Division
NICHOLAS CARTIER, CA Bar #235858
Trial Attorney, Federal Programs Branch
Civil Division
20 Massachusetts Ave NW, 7224
PO Box 883 (US Mail)
Washington, DC 20530
Tel: 202-616-8351
Fax: 202-616-8470
email: nicholas.cartier@usdoj.gov
Attorneys for Defendant
10
11
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
12
13
14
15
16
17
18
19
20
)
ELECTRONIC FRONTIER FOUNDATION, ) Case No. 10-CV-4892-RS
)
Plaintiff,
) STIPULATED REQUEST FOR ORDER
) TO CONTINUE ALL REMAINING
vs.
)
) DATES IN BRIEFING SCHEDULE
) FOR PARTIES’ CROSS-MOTIONS
DEPARTMENT OF JUSTICE,
) FOR SUMMARY JUDGMENT BY
) TWO WEEKS
)
Defendant.
) [CIV. L.R. 6-2]
)
)
21
22
Pursuant to Fed. R. Civ. P. 6(b)(1) and Civil L.R. 6-2, the parties, by and through their
23
undersigned counsel, have conferred and hereby stipulate to and respectfully request the Court
24
grant a two-week extension of the current deadline for Defendant to file an Opposition to
25
Plaintiff’s Cross-Motion for Summary Judgment and Reply in support of its Motion for Summary
26
27
28
Judgment and for Plaintiff to file a Reply in support of its Cross-Motion for Summary Judgment.
See 2/17/12 Order (ECF No. 36). The new schedule as proposed by the parties is as follows:
10-CV4892-RS
STIPULATION
1
Defendant files an Opposition to Plaintiff’s Cross-Motion
for Summary Judgment and Reply in support of
its Motion for Summary Judgment
April 26, 2012
4
Plaintiff files a Reply in support of its
Cross-Motion for Summary Judgment
May 17, 2010
5
Hearing on cross motions.
May 31, 2012
2
3
6
7
The requested changed will minimally affect the present schedule for the case because it
8
proposes continuing all dates, including the hearing date on the parties’ cross motions for summary
9
judgment, by two weeks. In accordance with Civil L.R. 6-2(a), this stipulation is supported by the
10
Declaration of Nicholas Cartier, counsel for Defendant.
11
The parties have previously stipulated to a briefing schedule (ECF No. 28) and to three
12
adjustments to that briefing schedule, two to accommodate the Defendant (ECF Nos. 32 and 36)
13
14
and the other to accommodate the Plaintiff (Dkt. 34). Defendant seeks the current two-week
15
extension to allow its three components (Criminal Division, DEA and FBI) to complete work on
16
supplemental declarations to address arguments raised in Plaintiff’s Cross-Motion and Opposition.
17
In addition, FBI requires this additional time to make corrections to the annotations on some of the
18
pages it produced to Plaintiff, which do not clearly indicate what exemption has been invoked with
19
respect to certain redactions on the pages.
20
The parties respectfully request that the schedule above be adopted in place of the schedule
21
22
23
previously proposed.
DATED: April 10, 2012
24
25
26
27
/s/ Nicholas Cartier
NICHOLAS CARTIER, CA Bar #235858
Trial Attorney, Federal Programs Branch
Civil Division
20 Massachusetts Ave NW, 7224
Washington, DC 20044
Tel: 202-616-8351
Fax: 202-616-8470
email: nicholas.cartier@usdoj.gov
Attorney for Defendant
28
10-CV4892-RS
STIPULATION
1
2
CERTIFICATE OF SERVICE
3
4
I hereby certify that on April 10, 2012, I caused a copy of the foregoing to be served on
Plaintiff via the Court’s ECF system.
5
6
/s/ Nicholas Cartier
NICHOLAS CARTIER
7
8
9
GENERAL ORDER NO. 45(X) CERTIFICATION
10
I attest that I have obtained the concurrence of Jennifer Lynch, counsel for Plaintiff, in the
11
12
filing of this document.
/s/ Nicholas Cartier
NICHOLAS CARTIER
13
14
15
16
PURSUANT TO STIPULATION, IT IS SO ORDERED.
17
18
Dated: 4/10/12
Hon. Richard Seeborg
United States District Judge
19
20
21
22
23
24
25
26
27
28
10-CV4892-RS
STIPULATION
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?