Hegar et al v. Panetta

Filing 72

STIPULATION AND ORDER re 71 For Continuance filed by Ashton Carter Case Management Statement due by 3/3/2016. Further Case Management Conference set for 3/10/2016 10:30 AM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 2/9/16. (bpf, COURT STAFF) (Filed on 2/9/2016)

1 ROSEMARIE T. RING (SBN 220769)
[e-mail]
2 MARI OVERBECK (SBN 261707)
[e-mail]
3 MUNGER, TOLLES & OLSON LLP
560 Mission Street
4 Twenty-Seventh Floor
San Francisco, California 94105-2907
5 Telephone:
[phone]
Facsimile:
[phone]
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CHRISTINE P. SUN (SBN 218701)
7 [e-mail]
ELIZABETH O. GILL (SBN 218311)
8 [e-mail]
AMERICAN CIVIL LIBERTIES UNION
9 FOUNDATION OF NORTHERN
CALIFORNIA, INC.
10 39 Drumm Street
San Francisco, CA 94111
11 Telephone:
[phone]
Facsimile:
[phone]
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Attorneys for Plaintiffs
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BENJAMIN MIZER
Principal Deputy Assistant Attorney General
BRIAN STRETCH
Acting United States Attorney
ALEX TSE
Chief, Civil Division
ANTHONY J. COPPOLINO
Deputy Branch Director
CAROLINE LEWIS WOLVERTON
[e-mail]
District of Columbia Bar No. 496433
Senior Trial Counsel
Civil Division, Federal Programs Branch
U.S. Department of Justice
P.O. Box 883
Washington, D.C. 20044
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant ASHTON B. CARTER

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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18 MARY JENNINGS HEGAR, JENNIFER
HUNT, ALEXANDRA ZOE BEDELL,
19 COLLEEN FARRELL, AND SERVICE
WOMEN’S ACTION NETWORK,
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Plaintiffs,
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vs.
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ASHTON B. CARTER, Secretary of Defense,
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Defendant.
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Case No. 12-CV-06005 EMC
STIPULATED REQUEST AND
[PROPOSED] ORDER FOR
CONTINUANCE OF FURTHER CMC and
UPDATED CMC STATEMENT
Judge: Hon. Edward M. Chen
Case Management Conference: Feb. 18, 2016
Time:
10:30 a.m.

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CASE NO. 12-6005 EMC
STIPULATED REQUEST AND [PROPOSED] ORDER

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STIPULATION
Plaintiffs Mary Jennings Hegar, Jennifer Hunt, Alexandra Zoe Bedell, Colleen Farrell and

3 Service Women’s Action Network and Defendant Ashton B. Carter, Secretary of Defense
4 (“Secretary”) (collectively, “the parties”), by and through their respective counsel, submit this
5 Stipulated Request and Proposed Order for a continuance of the deadline for the parties’ updated
6 joint Case Management Conference (CMC) Statement to February 25, 2016, and further CMC to
7 March 3, 2016. The joint CMC Statement is currently due February 11, 2016, and the further
8 CMC is currently scheduled for February 18, 2016. Defendant submits that the following facts
9 and circumstances set forth in the attached Declaration of counsel for Defendant Caroline Lewis
10 Wolverton establish good cause for the requested continuance as follows:
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1.

On November 20, 2015, the Court scheduled a further CMC in this matter for

12 February 18, 2016. ECF No. 67 (Nov. Nov. 20, 2015).
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2.

Subsequently, Ms. Wolverton’s son was selected for his middle school musical and

14 the musical was scheduled for the evening February 18, 2016. As the musical will be in Bethesda,
15 Maryland, Ms. Wolverton would not be able to return from San Francisco on February 18 in time
16 to attend the musical.
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3.

In light of the foregoing, Defendant respectfully requests that the Court continue

18 the deadline for the further CMC to March 3, 2016 and the parties’ updated joint CMC Statement
19 to February 25, 2016. Defendant requested and received Plaintiffs’ stipulation to this request.
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21 DATED: February 4, 2016
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BENJAMIN MIZER
Principal Deputy Assistant Attorney General
BRIAN STRETCH
Acting United States Attorney
ALEX TSE
Chief, Civil Division
ANTHONY J. COPPOLINO
Deputy Branch Director

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/s/
Caroline Lewis Wolverton
CAROLINE LEWIS WOLVERTON
U.S. Department of Justice
Attorneys for Defendant ASHTON B. CARTER
CASE NO. C-12-6005 EMC
STIPULATED REQUEST AND [PROPOSED] ORDER

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DATED: February 4, 2016

MUNGER, TOLLES & OLSON LLP

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By:

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/s/ Rosemarie T. Ring
ROSEMARIE T. RING

Attorneys for Plaintiffs
MARY JENNINGS HEGAR, JENNIFER HUNT,
ALEXANDRA ZOE BEDELL, COLLEEN FARRELL,
AND SERVICE WOMEN’S ACTION NETWORK

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8 Additional Counsel:
9 STEVEN M. PERRY (SBN 106154)
MUNGER, TOLLES & OLSON LLP
10 355 South Grand Avenue, 35th Floor
Los Angeles, CA 90071-1560
11 Telephone: [phone]
Facsimile: [phone]
12 Email: [e-mail]
13

LENORA M. LAPIDUS [pro hac vice]
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION
WOMEN’S RIGHTS PROJECT
125 Broad Street, 18th Floor
New York, NY 10004
Telephone:
[phone]
Facsimile:
[phone]
Email: [e-mail]

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ATTESTATION PURSUANT TO GENERAL ORDER 45

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I, Caroline Lewis Wolverton, am the ECF User whose identification and password are
being used to file this Stipulated Request and [Proposed] Order for Continuance of Further Case
Management Conference and Updated Case Management Statement. In compliance with General
Order 45.X.B, I hereby attest that all signatories have concurred in this filing.

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/s/

Caroline Lewis Wolverton

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CASE NO. C-12-6005 EMC
STIPULATED REQUEST AND [PROPOSED] ORDER

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[PROPOSED] ORDER

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Pursuant to the stipulated request, and based on good cause shown, it is hereby

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ORDERED that the Stipulated Request for Continuance of Further Case Management

4 Conference and Updated Case Management Statement is hereby GRANTED; and it is further
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ORDERED that the Further Case Management Conference is hereby CONTINUED to
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6 March 3, 2016; and it is further
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ORDERED that the deadline for the parties’ Updated Joint CMC Statement is
March 3, 2016
8 CONTINUED to February 25, 2016.
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O
IT IS S
IFIED
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HONORABLE EDWARD M. CHEN
United States ORDERED
District Judge

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UNIT
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2/9/16
10 Dated:

S DISTRICT
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CASE NO. C-12-6005 EMC
STIPULATED REQUEST AND [PROPOSED] ORDER