Cefalu v. Holder

Filing 61

STIPULATION AND ORDER re 58 STIPULATION WITH PROPOSED ORDER (Re Cleanupatf.org writings) filed by Eric H. Holder, Jr. Signed by Judge Jacqueline Scott Corley on January 11, 2013. (wsn, COURT STAFF) (Filed on 1/11/2013)

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MELINDA HAAG (CABN 132612)
United States Attorney
ALEX G. TSE (CSBN 152348)
Chief, Civil Division
JONATHAN U. LEE (CSBN 148792)
MARK R. CONRAD (CSBN 255667)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, CA 94102-3495
Telephone: [phone]
FAX: [phone]
[e-mail]; [e-mail]
Attorneys for Federal Defendant ERIC H. HOLDER
JR., U.S. Attorney General, U.S. Dept. of Justice
ZAHRA S. KARINSHAK (GABN 407911)
Admitted Pro Hac Vice 4/2/2012
KREVOLIN & HORST, LLC
1201 W. Peachtree Street, N.W.
Suite 3250, One Atlantic Center
Atlanta, GA 30309
Telephone: [phone]
FAX: [phone]
[e-mail]

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ANDREW D. WINGHART (CSBN 225099)
Winghart Law Group
495 Seaport Court, Suite 104
Redwood City, CA 94063
Telephone: [phone]
FAX: [phone]
[e-mail]
Attorneys for Plaintiff, Vincent A. Cefalu

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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VINCENT A. CEFALU,

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Plaintiff,

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v.

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ERIC H. HOLDER, JR., U.S. Attorney
General, U.S. Department of Justice,
Defendant,

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CASE NO. 12-00303-TEH
STIPULATION AND PROPOSED
ORDER

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THE PARTIES THROUGH THEIR ATTORNEYS OF RECORD STIPULATE AS FOLLOWS:

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1. On November 26, 2012, the Court issued an order (ECF 49) regarding defendant’s motion

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to compel plaintiff’s web-based writings about his employment that directed the parties to

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meet and confer on the best method for providing identification and authentication of
plaintiff’s web-based writings.
2. After meeting and conferring as directed by the Court, the parties agree that plaintiff wrote

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on the website known as www.cleanupatf.org, using three identifiers: (1) Vincent A

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Cefalu, (2) Doc Holiday, and (3) Iceman.

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3. Writings on www.cleauupatf.org by “Vincent A Cefalu” appear with the words “Vincent A
Cefalu” and next to the avatar of a badge copied below:

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VINCENT A CEFALU
Member Since 20 Jan 2010

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OFFLINE

4. Writings on www.cleanupatf.org by “Doc Holiday” appear with the words “Doc Holiday”
and next to the avatar copied below:

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Doc Holiday

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Joined 29-December 09
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5. Writings on www.cleanupatf.org by “Iceman” appear with the word “Iceman” and next to
the avatar copied below:

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Iceman

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Joined 19-October 10

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6. None of the writings by plaintiff using the identifiers Vincent A Cefalu, Doc Holiday, or
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Iceman have been deleted or removed from www.cleanupatf.org by plaintiff and all of
plaintiff’s writings are available to anyone accessing www.cleanupatf.org.
7. Upon a request made with reasonable notice, plaintiff will provide the electronic version of

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his writings on www.cleanupatf.org to counsel for the defendant, to the extent the writing is

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not publicly available on the site. Plaintiff shall undertake reasonable steps to locate said

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writing.

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8. Other than by using the identifiers Vincent A Cefalu, Doc Holiday, or Iceman, plaintiff has
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not written any writings appearing on www.cleanupatf.org.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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DATED:

1/10/2013

_/s Zahra Karinshak/_______.
Attorneys for Plaintiff

DATED: 1/10/2013

_/s Jonathan U. Lee/________.
Attorneys for Defendant

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED: January 11, 2013

________________________________
JACQUELINE S. CORLEY
United States Magistrate Judge

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