Public.Resource.org v. United States Internal Revenue Service
Filing
78
STIPULATION WITH PROPOSED ORDER Extending Plaintiff's Time to Move for Attorney's Fees filed by United States Internal Revenue Service. (Sanders, Christopher) (Filed on 4/22/2015)
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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: (415) 276-6500/Fax: (415) 276-6599
Email:
thomasburke@dwt.com
DAN LAIDMAN (CA State Bar No. 274482)
DAVIS WRIGHT TREMAINE LLP
865 South Figueroa Street, Suite 2400
Los Angeles, CA 90017-2566
Phone: (213) 633-6800/Fax: (213) 633-6899
Email:
danlaidman@dwt.com
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DAVID HALPERIN (Pro Hac Vice)
1530 P Street NW
Washington, DC 20005
Telephone:
(202) 905-3434
Email:
davidhalperindc@gmail.com
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Attorneys for Plaintiff Public.Resource.Org
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MELINDA HAAG
United States Attorney
CAROLINE D. CIRAOLO
Acting Assistant Attorney General, Tax Division
CHRISTOPHER W. SANDERS
Trial Attorney, Tax Division, U.S. Department of Justice
Post Office Box 227, Ben Franklin Station
Washington, D.C. 20044
Phone: (202) 616-1840/Fax: (202) 514-6866
Email: Christopher.W.Sanders@usdoj.gov
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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
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SERVICE,
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Defendant.
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Case No. 13-cv-02789 WHO
STIPULATION AND [PROPOSED]
ORDER EXTENDING DEFENDANT’S
DEADLINE FOR PRODUCTION OF
DOCUMENTS AND PLAINTIFF’S
DEADLINE TO MOVE TO RECOVER
ATTORNEYS’ FEES AND COSTS
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1
STIPULATION AND [PROPOSED] ORDER EXTENDING DEFENDANT’S DEADLINE FOR PRODUCTION OF DOCUMENTS AND
PLAINTIFF’S DEADLINE TO MOVE TO RECOVER ATTORNEYS’ FEES AND COSTS
Case No. 13-cv-02789-WHO
12643314.1
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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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WHEREAS, Plaintiff intends to move to recover attorneys’ fees and costs pursuant to 5
U.S.C. § 552(a)(4)(E);
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WHEREAS, the Plaintiff’s Fee Motion is currently due by May 5, 2015;
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WHEREAS, the parties agree that an extension of Plaintiff’s deadline to file a Fee Motion
DAVIS WRIGHT TREMAINE LLP
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will allow the parties additional time to confer and consider attorneys’ fees and costs issues that
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could lead to narrowing issues to be presented in a future motion for fees and costs, or to
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eliminating the need to file such a motion;
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NOW THEREFORE, IT IS HEREBY STIPULATED THAT:
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Plaintiff’s deadline to file a motion to recover attorneys’ fees and costs shall be
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extended until June 5, 2015.
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IT IS SO STIPULATED.
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DATED this 22nd day of April, 2015.
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MELINDA HAAG
United States Attorney
CAROLINE D. CIRAOLO
Acting 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
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STIPULATION AND [PROPOSED] ORDER EXTENDING DEFENDANT’S DEADLINE FOR PRODUCTION OF DOCUMENTS AND
PLAINTIFF’S DEADLINE TO MOVE TO RECOVER ATTORNEYS’ FEES AND COSTS
Case No. 13-cv-02789-WHO
12643314.1
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ATTESTATION PURSUANT TO GENERAL ORDER 45
I, Christopher W. Sanders, hereby attest that concurrences in the filing of this document
have been obtained from each of the signatories.
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/s/ Christopher W. Sanders
Christopher W. Sanders
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[PROPOSED] ORDER
Pursuant to the parties’ stipulation, and good cause appearing, the foregoing is approved
and IT IS SO ORDERED.
DAVIS WRIGHT TREMAINE LLP
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Date: ____________________
_________________________________
United States District Court Judge
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STIPULATION AND [PROPOSED] ORDER EXTENDING DEFENDANT’S DEADLINE FOR PRODUCTION OF DOCUMENTS AND
PLAINTIFF’S DEADLINE TO MOVE TO RECOVER ATTORNEYS’ FEES AND COSTS
Case No. 13-cv-02789-WHO
12643314.1
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