Electronic Frontier Foundation v. Department of Commerce

Filing 34

STIPULATION AND ORDER Continuing Summary Judgment Hearing Date re 33 : Set/Reset Deadlines as to re 22 Cross MOTION for Summary Judgment, and re 20 First MOTION for Summary Judgment. Motion Hearing set for 6/10/2013 at 10:00 AM in Courtroom 2, 17th Floor, San Francisco before Hon. Thelton E. Henderson. Signed by Judge Thelton E. Henderson on 05/15/2013. (tmi, COURT STAFF) (Filed on 5/16/2013)

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Mark Rumold (SBN 279060)
[e-mail]
Jennifer Lynch (SBN 240701)
[e-mail]
ELECTRONIC FRONTIER FOUNDATION
815 Eddy Street
San Francisco, CA 94109
Telephone: [phone]
Facsimile: [phone]
Attorney for Plaintiff
Electronic Frontier Foundation

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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, ) Case No. 3:12-cv-3683-TEH
)
Plaintiff,
)
) STIPULATED REQUEST AND
v.
) [PROPOSED] ORDER FOR
) CONTINUANCE OF SUMMARY
DEPARTMENT OF COMMERCE,
) JUDGMENT HEARING DATE
)
Defendant.
) Date: May 20, 2013
) Time: 10:00 a.m.
) Place: Courtroom 2, 17th Floor
) Judge: Hon. Thelton E. Henderson
)

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STIPULATION AND [PROPOSED] ORDER
Case No.: 12-cv-3683 TEH

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Plaintiff Electronic Frontier Foundation and Defendant Department of Commerce

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respectfully submit the following Stipulated Request and Proposed Order continuing the hearing

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date on the parties’ cross-motions for summary judgment until June 10, 2013. Good cause exists

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for this Stipulated Request as follows:
1.

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The hearing on the parties’ cross-motion was scheduled for May 6, 2013. Due to

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illness of Defendant’s counsel (ECF No. 29) and the Court’s own continuance (ECF No. 32), the

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hearing is currently scheduled for May 20, 2013.
2.

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Due to a previously scheduled conflict, Plaintiff’s counsel is unavailable on May 20,

2013. May 27, 2013 is a federal holiday. Neither Plaintiff’s nor Defendant’s counsel are available

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on June 3, 2013.

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Therefore, the parties stipulate that the hearing date be continued until June 10,

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Granting this Stipulated Request will not alter or extend any other dates or deadlines

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2013.

currently pending in this matter.
WHEREFORE, the parties respectfully request that the Court grant this Stipulated Request
and continue the hearing date on the parties’ cross-motions until June 10, 2013.
Respectfully submitted,

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DATED: May 15, 2013

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/s/ Mark Rumold
MARK RUMOLD
Electronic Frontier Foundation
815 Eddy Street
San Francisco, CA 94109
Telephone: [phone]
Facsimile: [phone]

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Counsel for Plaintiff

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DATED: May 15, 2013

MELINDA HAAG
United States Attorney
ALEX G. TSE
Chief, Civil Division
/s/ Victoria Carradero (with permission)
VICTORIA CARRADERO
Assistant United States Attorney
450 Golden Gate Ave, Box 36055
San Francisco, CA 94102
Counsel for Defendant
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STIPULATION AND [PROPOSED] ORDER
Case No.: 12-cv-3683-TEH

DECLARATION PURSUANT TO LOCAL RULE 5-1

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I, Mark Rumold, attest that I have obtained the concurrence of Victoria Carradero, Counsel
for Defendant, in the filing of this document.
Executed on May 15, 2013, in San Francisco, California.

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/s/ Mark Rumold
Mark Rumold

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June 10, 2013.

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S

helton E

Judge T

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__________________
The Honorable Thelton E. Henderson
United States District enderson
Court Judge
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05/15/2013
DATED: ____________________

UNIT
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ISTRIC
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The hearing date for the parties’ cross-motions for summary judgment is continued until

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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STIPULATION AND [PROPOSED] ORDER
Case No.: 12-cv-3683-TEH

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