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)

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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

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