Electronic Frontier Foundation v. Department of Justice

Filing 77

STIPULATION AND ORDER TO CONTINUE DEADLINE TO FILE A PROPOSED JUDGMENT TERMINATING THE ACTION. Signed by Judge Richard Seeborg on 11/26/13. (cl, COURT STAFF) (Filed on 11/26/2013)

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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: [phone]
Fax: [phone]
email: [e-mail]
Attorneys for Defendant

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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)
ELECTRONIC FRONTIER FOUNDATION, ) Case No. 10-CV-4892-RS
) ORDER
Plaintiff,
) STIPULATED REQUEST FOR ORDER
) TO CONTINUE DEADLINE TO FILE
vs.
)
) A PROPOSED JUDGMENT
) TERMINATING THIS ACTION
DEPARTMENT OF JUSTICE,
)
) [CIV. L.R. 6-2]
)
Defendant.
)
)
)

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The Court has ordered the parties to submit a proposed judgment to terminate this action by

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December 2, 2013. Order Re Renewed Cross-Motions for Summary Judgment (ECF No. 75) at 10.

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For the reasons discussed below, the parties have stipulated to and request a one-week extension of
this deadline until December 9, 2013.

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In response to the Court’s Summary Judgment Order, the Criminal Division, Federal

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Bureau of Investigation, and Drug Enforcement Administration (collectively, “DOJ Components”)
10-CV4892-RS

STIPULATION

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processed and mailed out certain additional documents to Plaintiff on November 21, 2013. Id. The

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materials were inadvertently sent to Plaintiff’s prior address. As a result, counsel for Plaintiff has

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not yet received the materials, and due to work-related travel, likely will not be able to review the

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materials before the Thanksgiving holiday weekend. In addition, Government counsel has
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preexisting international travel plans from November 28, 2013 through December 4, 2013.

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Therefore, a one-week extension is needed to allow Plaintiff adequate time to review the DOJ

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Components’ productions and for the parties to meet and confer regarding a proposed judgment

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terminating this action.

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The requested changed will not affect any other dates in the present schedule.

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DATED: November 26, 2013
/s/ Nicholas Cartier
NICHOLAS CARTIER, CA Bar #235858
Trial Attorney, Federal Programs Branch
Civil Division
20 Massachusetts Ave NW, 7224
Washington, DC 20044
Tel: [phone]
Fax: [phone]
email: [e-mail]
Attorney for Defendant

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CERTIFICATE OF SERVICE

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I hereby certify that on November 26, 2013, I caused a copy of the foregoing to be served
on Plaintiff via the Court’s ECF system.

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/s/ Nicholas Cartier
NICHOLAS CARTIER

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10-CV4892-RS

STIPULATION

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GENERAL ORDER NO. 45(X) CERTIFICATION

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I attest that I have obtained the concurrence of Jennifer Lynch, counsel for Plaintiff, in the
filing of this document.

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/s/ Nicholas Cartier
NICHOLAS CARTIER

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Pursuant to stipulation, the parties shall jointly file a proposed judgment terminating this

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action no later than December 9, 2013. SO ORDERED.

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Dated: 11/26/13
Hon. Richard Seeborg
United States District Judge

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10-CV4892-RS

STIPULATION