Electronic Frontier Foundation v. Department of Commerce

Filing 17

STIPULATION AND ORDER on Summary Judgment Briefing Schedule re 16 . Signed by Judge Thelton E. Henderson on 10/18/2012. (tmi, COURT STAFF) (Filed on 10/19/2012)

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Mark Rumold (SBN 279060)
[e-mail]

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Jennifer Lynch (SBN 240701)
[e-mail]
ELECTRONIC FRONTIER FOUNDATION
454 Shotwell Street
San Francisco, CA 94110
Telephone: [phone]
Facsimile: [phone]

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Attorney for Plaintiff
Electronic Frontier Foundation
MELINDA HAAG (CABN 132612)
United States Attorney
ALEX G. TSE (CSBN 152348)
Chief, Civil Division
VICTORIA R. CARRADERO (CABN 217885)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: [phone]
FAX: [phone]
Email: [e-mail]

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Attorneys for Federal Defendant
United States Department of Commerce

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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,
Plaintiff,

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v.
DEPARTMENT OF COMMERCE,
Defendant.

)
) Case No. 3:12-cv-3683-TEH
)
)
) STIPULATION AND [PROPOSED] ORDER ON
) SUMMARY JUDGMENT BRIEFING
) SCHEDULE
)
) Place: Courtroom 12, 19th Floor
) Judge: Hon. Thelton E. Henderson
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)
)
)

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STIPULATION AND [PROPOSED] ORDER
CASE NO. 12-3683 TEH

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Plaintiff Electronic Frontier Foundation (“EFF”) and Federal Defendant the United States

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Department of Commerce respectfully submit the stipulation on summary judgment briefing in this

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matter and request that the Court order the same.

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Defendant will file its Motion for Summary Judgment on January 21, 2013. Defendant will
have 30 pages for its opening brief.
Plaintiff will file a combined Opposition to Defendant’s Motion/Cross-Motion for

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Summary Judgment on February 20, 2013.

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Opposition/Cross-Motion.

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Plaintiff will have 30 pages for its combined

Defendant will file a combined Opposition to Plaintiff’s Cross-Motion/Reply brief in

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support of its motion on March 22, 2013.

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Opposition/Reply brief.

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Defendant will have 30 pages for its combined

Plaintiff will file a Reply brief in support of its Motion for Summary Judgment on April 5,
2013. Plaintiff will have 15 pages for its reply.

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The hearing on the parties’ Motions for Summary Judgment will be held on April 29, 2013.

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Unless the Court feels otherwise, the parties agree to vacate the Case Management

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Conference currently set for Monday, October 22, 2012.

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DATED: October 18, 2012

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/s/ Mark Rumold
ELECTRONIC FRONTIER FOUNDATION
Mark Rumold, Esq.
454 Shotwell Street
San Francisco, CA 94110
Telephone: [phone]
Facsimile: [phone]

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Attorney for Plaintiff

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Respectfully submitted,

MELINDA HAAG
United States Attorney

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________/s/_____________________
Victoria Carradero
Assistant U.S. Attorney
Attorneys for Federal Defendant

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STIPULATION AND [PROPOSED] ORDER
CASE NO. 12-3683 TEH

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DECLARATION PURSUANT TO GENERAL ORDER 45
I, Victoria R. Carradero, attest that I have obtained the concurrence of Mark Rumold,
Counsel for Plaintiff, in the filing of this document.
Executed on October 18, 2012, in San Francisco, California.
/s/ Victoria R. Carradero
Victoria R. Carradero

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STIPULATION AND [PROPOSED] ORDER
CASE NO. 12-3683 TEH

PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Defendant will file its Motion for Summary Judgment on January 21, 2013. Defendant will
have 30 pages for its opening brief.
Plaintiff will file a combined Opposition to Defendant’s Motion/Cross-Motion for
Summary Judgment on February 20, 2013.
Opposition/Cross-Motion.
Defendant will file a combined Opposition to Plaintiff’s Cross-Motion/Reply brief in
support of its motion on March 22, 2013.

Defendant will have 30 pages for its combined

Opposition/Reply brief.
Plaintiff will file a Reply brief in support of its Motion for Summary Judgment on April 5,
2013. Plaintiff will have 15 pages for its reply.
The hearing on the parties’ Motions for Summary Judgment will be held on April 29, 2013.
The Case Management Conference currently set for Monday, October 22, 2012 is
VACATED.

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UNIT
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DATE: October ___. 2012

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Plaintiff will have 30 pages for its combined

___________________________________
The Honorable Thelton E. Henderson
United States District Court Judge

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STIPULATION AND [PROPOSED] ORDER
CASE NO. 12-3683 TEH

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