Public.Resource.org v. United States Internal Revenue Service

Filing 66

STIPULATION AND ORDER EXTENDING PLAINTIFF'S TIME TO MOVE TO RECOVER ATTORNEYS FEES AND COSTS re 64 STIPULATION. Plaintiff's deadline to file a motion to recover attorneys fees and costs shall be extended until March 16, 2015. Signed by Judge William H. Orrick on 02/10/2015. (jmdS, COURT STAFF) (Filed on 2/10/2015)

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THOMAS R. BURKE (CA State Bar No. 141930)
RONALD G. LONDON (Pro Hac Vice)
DAVIS WRIGHT TREMAINE LLP
505 Montgomery Street, Suite 800
San Francisco, California 94111
Phone: [phone]/Fax: [phone]
Email:
[e-mail]
DAN LAIDMAN (CA State Bar No. 274482)
DAVIS WRIGHT TREMAINE LLP
865 South Figueroa Street, Suite 2400
Los Angeles, CA 90017-2566
Phone: [phone]/Fax: [phone]
Email:
[e-mail]

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DAVID HALPERIN (Pro Hac Vice)
1530 P Street NW
Washington, DC 20005
Telephone:
[phone]
Email:
[e-mail]

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Attorneys for Plaintiff Public.Resource.Org

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MELINDA HAAG
United States Attorney
CAROLINE D. CIRAOLO
Principal Deputy Assistant Attorney General, Tax Division
CHRISTOPHER W. SANDERS
Trial Attorneys, Tax Division, U.S. Department of Justice
Post Office Box 227, Ben Franklin Station
Washington, D.C. 20044
Phone: [phone]/Fax: [phone]
Email: [e-mail]

DAVIS WRIGHT TREMAINE LLP

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Attorneys for Defendant United States Internal Revenue Service
IN THE UNITED STATES DISTRICT COURT
THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
PUBLIC.RESOURCE.ORG., a California non- )
profit organization,
)
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Plaintiff,
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v.
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UNITED STATES INTERNAL REVENUE
)
SERVICE,
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Defendant.
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)

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Case No. 13-cv-02789 WHO
STIPULATION AND ORDER
EXTENDING PLAINTIFF’S TIME TO
MOVE TO RECOVER ATTORNEYS’
FEES AND COSTS

STIPULATION AND ORDER EXTENDING TIME TO MOVE TO RECOVER ATTORNEYS’ FEES AND COSTS
Case No. 13-cv-02789-WHO
DWT 26130492v1 0200593-000001

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The parties, through their respective counsel of record, submit the following stipulation
and request that the Court issue an order as requested:
WHEREAS, on January 29, 2015, this Court granted the Motion for Summary Judgment

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of Plaintiff Public.Resource.Org, denied the Motion for Summary Judgment of Defendant United

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States Internal Revenue Service, and entered Judgment in favor of Plaintiff;

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DAVIS WRIGHT TREMAINE LLP

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WHEREAS, Plaintiff intends to move to recover attorneys’ fees and costs pursuant to 5
U.S.C. § 552(a)(4)(E);
WHEREAS, under Federal Rule of Civil Procedure 54(d) and Northern District Local Rule
54-5, Plaintiff’s Fee Motion is currently due by February 12, 2015;
WHEREAS, the parties agree that an extension of Plaintiff’s deadline to file a Fee Motion
might help to facilitate a resolution of the fee issue that would not require a motion;

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NOW THEREFORE, IT IS HEREBY STIPULATED THAT:

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1. Plaintiff’s deadline to file a motion to recover attorneys’ fees and costs shall be

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extended until March 16, 2015.

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IT IS SO STIPULATED.

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DATED this __th day of February, 2015.

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MELINDA HAAG
United States Attorney
CAROLINE D. CIRAOLO
Principal Deputy Assistant Attorney General,
Tax Division
CHRISTOPHER W. SANDERS
Trial Attorney, Tax Division
By: /s/ Christopher W. Sanders
CHRISTOPHER W. SANDERS
Attorneys for Defendant United States Internal
Revenue Service

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DAVIS WRIGHT TREMAINE LLP
By: /s/ Thomas R. Burke
THOMAS R. BURKE
Attorneys for Plaintiff Public.Resource.Org

ATTESTATION PURSUANT TO GENERAL ORDER 45
I, Thomas R. Burke, hereby attest that concurrences in the filing of this document have
been obtained from each of the signatories.

/s/ Thomas R. Burke
Thomas R. Burke
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STIPULATION AND ORDER EXTENDING TIME TO MOVE TO RECOVER ATTORNEYS’ FEES AND COSTS
Case No. 13-cv-02789-WHO
DWT 26130492v1 0200593-000001

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ORDER
Pursuant to the parties’ stipulation, and good cause appearing, the foregoing is approved
and IT IS SO ORDERED.

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Date: February 10, 2015

________________________________
United States District Court Judge

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DAVIS WRIGHT TREMAINE LLP

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STIPULATION AND ORDER EXTENDING TIME TO MOVE TO RECOVER ATTORNEYS’ FEES AND COSTS
Case No. 13-cv-02789-WHO
DWT 26130492v1 0200593-000001