Almy et al v. United States Department of Defense et al

Filing 78

Joint MOTION to Stay Current Briefing Schedule and to Create Briefing Schedule on Motion for Protective Order filed by Michael D. Almy. Responses due by 8/23/2012. Replies due by 8/30/2012. (Attachments: # 1 Declaration Jessica Roberts)(Roberts, Jessica) (Filed on 8/9/2012)

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M. ANDREW WOODMANSEE (CA SBN 201780)
[e-mail]
STEPHANIE L. FONG (CA SBN 240836)
[e-mail]
KIMBERLY R. GOSLING (CA SBN 247803)
[e-mail]
JESSICA A. ROBERTS (CA SBN 265570)
[e-mail]
MORRISON & FOERSTER LLP
12531 High Bluff Drive
San Diego, California 92130-2040
Telephone: [phone]
Facsimile: 858.720.5125
JOHN M. GOODMAN (DC SBN 383147)
[e-mail]
SERVICEMEMBERS LEGAL DEFENSE NETWORK
P. O. Box 65301
Washington, DC 20035-5301
Telephone: [phone]
Facsimile: 202.797.1635
Attorneys for Plaintiff
MICHAEL D. ALMY

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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MICHAEL ALMY, JASON KNIGHT, and
ANTHONY LOVERDE,

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Plaintiffs,
v.
UNITED STATES DEPARTMENT OF
DEFENSE; ROBERT M. GATES, Secretary
of Defense; DEPARTMENT OF THE AIR
FORCE; MICHAEL B. DONLEY, Secretary,
Department of the Air Force; DEPARTMENT
OF THE NAVY; and RAY MABUS,
Secretary, Department of the Navy,

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Case No. cv 10-5627 (RS)
DECLARATION OF
JESSICA ROBERTS IN SUPPORT OF
STIPULATED JOINT
ADMINISTRATIVE MOTION AND
[PROPOSED] ORDER FOR STAY OF
CURRENT BRIEFING SCHEDULE
AND TO CREATE BRIEFING
SCHEDULE ON MOTION FOR
PROTECTIVE ORDER

Defendants.

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DECLARATION OF JESSICA ROBERTS ISO JOINT STIPULATED ADMIN MOTION

sd-597824

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I, Jessica Roberts, hereby declare as follows:

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1.

I am a member of the bar of the State of California. I am an associate with the law

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firm of Morrison & Foerster LLP, counsel for plaintiff Michael D. Almy. I have personal

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knowledge of the facts set forth herein, and if called upon to do so, I could and would testify

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competently thereto.

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2.

On August 10, 2012, Defendants in this matter are scheduled to file their

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Opposition to Plaintiff Almy’s motion for summary judgment and their own motion to dismiss, or

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in the alternative, motion for summary judgment. See ECF No. 77.

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3.

Defendants have indicated that they intend to attach documents and quote from

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documents that Plaintiff believes should be filed under seal. Defendants disagree with Plaintiff’s

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assessment of the confidentiality of these materials and, pursuant to Federal Regulation 29 CFR

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50.9, believe that it is appropriate to file them on the public record.

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4.

Until the Court resolves Plaintiff’s Motion for a Protective Order, the Parties

propose to stay the briefing schedule in this matter.

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5.

The briefing schedule at issue has been continued twice before. ECF No. 73, 76.

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6.

The proposed stay would continue the briefing until five (5) business days after the

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Court’s ruling on the Protective Order, and then continue pursuant to a revised briefing schedule

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ordered by the Court.

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I declare under penalty of perjury that the foregoing is true and correct.

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Executed on August 9, 2012, at San Diego, California.

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By: /s/ Jessica Roberts
Jessica Roberts
[e-mail]

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MORRISON & FOERSTER LLP
Attorneys for Plaintiff
Michael D. Almy

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DECLARATION OF JESSICA ROBERTS ISO JOINT STIPULATED ADMIN MOTION

sd-597824

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CERTIFICATE OF SERVICE
I hereby certify that all counsel of record, who are deemed to have consented to electronic
service, are being served this 9th day of August, 2012, with a copy of this document via the
Court’s CM/ECF system.

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/s/ Jessica Roberts
Jessica Roberts

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DECLARATION OF JESSICA ROBERTS ISO JOINT STIPULATED ADMIN MOTION

sd-597824

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