Public.Resource.org v. Sheet Metal and Air Conditioning Contractors' National Association, Inc.

Filing 35

STIPULATION AND ORDER to Extend Time to Reply. Set/Reset Deadlines as to 22 MOTION for Default Judgment by the Court. Replies due by 6/27/2013. Signed by Judge Samuel Conti on 06/19/2013. (tmi, COURT STAFF) (Filed on 6/20/2013)

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CORYNNE MCSHERRY (221504)
[e-mail]
MATTHEW ZIMMERMAN (212423)
[e-mail]
ELECTRONIC FRONTIER FOUNDATION
454 Shotwell Street
San Francisco, CA 94110
Telephone: [phone]
Facsimile: [phone]
DAVID HALPERIN (Admitted Pro Hac Vice)
[e-mail]
3333 14th Street NW, Suite 205
Washington, DC 20010

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LAW
AT

MOUNTAI N VI EW

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ATTO RNEY S

F ENWICK & W ES T LLP

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ANDREW P. BRIDGES (CSB No. 122761)
[e-mail]
JAMES J. VARELLAS III (CSB No. 253633)
[e-mail]
KATHLEEN LU (CSB No. 267032)
[e-mail]
FENWICK & WEST LLP
555 California Street, 12th Floor
San Francisco, CA 94104
Telephone:
415.875.2300
Facsimile:
415.281.1350

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Attorneys for Plaintiff
PUBLIC.RESOURCE.ORG

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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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PUBLIC.RESOURCE.ORG,
Plaintiff,

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Case No.: 3:13-cv-00815 SC
STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME TO
REPLY

v.

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SHEET METAL AND AIR CONDITIONING
CONTRACTORS’ NATIONAL
ASSOCIATION, INC.,

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Defendant.

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STIPULATION AND [PROPOSED] ORDER

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Case No.: 3:13-cv-00815 SC

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STIPULATION
Counsel for Plaintiffs Public.Resource.Org (“Public Resource”) and Defendant Sheet

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Metal and Air Conditioning Contractors’ National Association, Inc. (“SMACNA”) (collectively,

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the “Parties”) enter into the following Stipulation and [Proposed] order:

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WHEREAS, Public Resource filed its motion for default judgment (Dkt. No. 22) on May
29, 2013 and personally served SMACNA, noticing a hearing date of July 19th, 2013;
WHEREAS, according to Public Resource’s calculation, SMACNA’s response to that

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motion was due on June 12, 2013, with any further reply from Public Resource due 7 days later,

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on June 19, 2013;

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LAW
AT

MOUNTAI N VI EW

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ATTO RNEY S

F ENWICK & W ES T LLP

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WHEREAS, SMACNA filed its partial opposition to the motion for default judgment on
June 17, 2013, calculated at 14 days plus 3 days from the date of Public Resource’s motion;
In the interest of allowing Public Resource sufficient time to reply, the parties agree that

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Public Resource should receive until June 27, 2013, calculated at 7 days plus 3 days from

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SMACNA’s filing, to file its reply and any supporting papers.

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This extension will not affect the Court’s calendar. No previous extensions or time

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modifications have been requested or ordered. The noticed hearing date of July 19th, 2013 is 23

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days after the proposed date for Public Resource to submit its papers. The parties do not request a

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change of the noticed hearing date, and this extension will not affect any other court date or the

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schedule of this case.

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NOW THEREFORE, the Parties, by and through their respective counsel of record,
hereby stipulate, subject to Court approval, as follow:
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Plaintiff Public.Resource.Org, Inc.’s reply and supporting papers on its motion for

default judgment (Dkt. No. 22) is due June 27, 2013.

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IT IS SO STIPULATED.

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STIPULATION AND [PROPOSED] ORDER

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Case No.: 3:13-cv-00815 SC

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Dated: June 18, 2013

FENWICK & WEST LLP

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By: /s/ Kathleen Lu
Kathleen Lu

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Attorneys for Plaintiff
PUBLIC.RESOURCE.ORG

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Dated: June 18, 2013

MORRISON & FOERSTER LLP

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By: /s/ Nicholas S. Napolitan
Nicholas S. Napolitan

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Attorneys for Plaintiff
SHEET METAL AND AIR CONDITIONING
CONTRACTORS’ NATIONAL
ASSOCIATION, INC.

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Pursuant to stipulation, it is SO ORDERED.
S

06/19/2013
Dated:___________________

onti
amuel C

NO

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RT

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Judge S

ER

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A

H

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R NIA

Honorable Samuel Conti
United States District Judge

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FO

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RT
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S DISTRICT
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[PROPOSED] ORDER

UNIT
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LAW
AT

MOUNTAI N VI EW

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ATTO RNEY S

F ENWICK & W ES T LLP

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N

F
D IS T IC T O
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STIPULATION AND [PROPOSED] ORDER

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Case No.: 3:13-cv-00815 SC