Electronic Frontier Foundation v. Department of Justice

Filing 70

STIPULATION AND ORDER RE 69 TO CONTINUE HEARING DATE FOR PARTIES' RENEWED CROSS MOTIONS FOR SUMMARY JUDGMENT. Motion Hearing set for 5/30/2013 01:30 PM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Signed by Judge Richard Seeborg on 4/22/13. (cl, COURT STAFF) (Filed on 4/22/2013)

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Jennifer Lynch (SBN 240701)
[e-mail]
ELECTRONIC FRONTIER FOUNDATION
815 Eddy Street
San Francisco, CA 94109
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]
v.
) ORDER TO CONTINUE HEARING
) DATE FOR PARTIES’ RENEWED
DEPARTMENT OF JUSTICE,
) CROSS MOTIONS FOR SUMMARY
) JUDGMENT
Defendant.
)
) [Civ. L.R. 6-2]
)
) Date:
April 25, 2013
) Time:
2:30 p.m.
) Place:
Ctrm. 3, 17th Floor
) Judge:
Hon. Richard Seeborg
)
)
)

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Case No. CV-10-04892-RS
STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING DATE FOR PARTIES’
RENEWED 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 a continuance to the hearing date for the parties’ Renewed Cross Motions for Summary

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Judgment. The hearing date is currently scheduled for Thursday, April 25, 2013, and the parties

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request the hearing be continued to Thursday, May 30, 2013.

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The parties seek this continuance because Plaintiff’s counsel’s grandmother passed away

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today, and plaintiff’s counsel needs to travel to be with family and to help her family with the

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logistics surrounding her grandmother’s death. Defendant’s counsel’s schedule is full with other

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matters throughout the month of May, and so May 30, 2013 is the first date both counsel will be

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available.

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

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Renewed Cross Motions are fully briefed and because it will only extend the hearing date by about

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a month.

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DATED: April 19, 2013

Respectfully submitted,

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/s/ Jennifer Lynch
Jennifer Lynch
ELECTRONIC FRONTIER FOUNDATION
815 Eddy Street
San Francisco, CA 94109
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff
ELECTRONIC FRONTIER FOUNDATION

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/s/ Nicholas Cartier
(with permission)
NICHOLAS CARTIER
Trial Attorney, Federal Programs Branch
Civil Division, U.S. DEPARTMENT OF JUSTICE
20 Massachusetts Ave NW, 7224
PO Box 883 (US Mail)
Washington, DC 20530
Tel: [phone]
Fax: [phone]
email: [e-mail]

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Attorneys for Defendants

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DATED: April 19, 2013

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Case No. CV-10-04892-RS

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING DATE
FOR PARTIES’ RENEWED CROSS MOTIONS FOR SUMMARY JUDGMENT

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DECLARATION PURSUANT TO LOCAL RULE 5-1

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I, Jennifer Lynch, hereby declare pursuant to Local Rule 5-1 that I have obtained

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

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Defendant.

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Executed on April 19, 2013, in San Francisco, California.

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/s/ Jennifer Lynch
Jennifer Lynch

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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4/22/13
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 HEARING DATE
FOR PARTIES’ RENEWED CROSS MOTIONS FOR SUMMARY JUDGMENT