Electronic Frontier Foundation v. Department of Justice

Filing 81

STIPULATED REQUEST FOR ORDER TO CONTINUE DEADLINE TO FILE PROPOSED JUDGMENT TERMINATING THIS ACTION OR FILE A JOINT STATUS REPORT. Signed by Judge Richard Seeborg on 12/16/13. (cl, COURT STAFF) (Filed on 12/17/2013)

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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
)
Plaintiff,
) STIPULATED REQUEST FOR ORDER
) TO CONTINUE DEADLINE TO FILE
vs.
)
) A PROPOSED JUDGMENT
) TERMINATING THIS ACTION OR
DEPARTMENT OF JUSTICE,
) TO FILE A JOINT STATUS REPORT
) [CIV. L.R. 6-2]
)
Defendant.
)
)
)

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Pursuant to the Court’s December 9, 2013 Order, see ECF No. 78, the parties submit the

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following status report to apprise the Court of their efforts to resolve a potential dispute about the

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scope of the Court’s summary judgment order. ECF No. 77. The parties, through their counsel,
met and conferred on December 9 and December 16, 2013, but have not yet been able to come to

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agreement on all outstanding matters that remain in contention. The parties believe that additional
time will assist them in their efforts to resolve the current impasse. In light of the upcoming
10-CV4892-RS

STIPULATION

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holidays, the parties have stipulated to and request that within 30 days, or no later than January 15,

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2013, the parties will either file a proposed judgment terminating this action or file a joint status

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report clarifying any issues that remain in dispute which require court intervention to resolve.

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The requested change will not affect any other dates in the present schedule.
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DATED: December 16, 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 December 16, 2013, I caused a copy of the foregoing to be served
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on Plaintiff via the Court’s ECF system.

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/s/ Nicholas Cartier
NICHOLAS CARTIER

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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

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filing of this document.

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/s/ Nicholas Cartier
NICHOLAS CARTIER

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10-CV4892-RS

STIPULATION

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Pursuant to stipulation, by no later than January 15, 2014, the parties shall either jointly file
a proposed judgment terminating this action, of if the parties cannot agree on the terms of a
proposed judgment, then the parties shall file a status report setting forth the nature of the parties’

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dispute that requires court intervention. SO ORDERED.
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Dated: 12/16/13
Hon. Richard Seeborg
United States District Judge

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10-CV4892-RS

STIPULATION