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

Filing 95

MOTION for Leave to File Sur-Reply in Opposition to Plaintiff's Motion for Attorneys' Fees filed by United States Internal Revenue Service. (Attachments: # 1 Declaration of Stephen S. Ho, # 2 Exhibit A - Proposed Sur-Reply, # 3 Proposed Order)(Ho, Stephen) (Filed on 8/26/2015)

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MELINDA L. HAAG
United States Attorney
CAROLINE D. CIRAOLO
Acting Assistant Attorney General
STEPHEN S. HO
Trial Attorney, Tax Division
U.S. Department of Justice
Post Office Box 227
Washington, D.C. 20044
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendant United States
Internal Revenue Service

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IN THE UNITED STATES DISTRICT COURT

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THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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PUBLIC.RESOURCE.ORG., a California non- ) Case No. 13-cv-02789-WHO
profit organization,
)
) DECLARATION OF STEPHEN S. HO
Plaintiff,
)
)
v.
)
)
UNITED STATES INTERNAL REVENUE
)
SERVICE,
)
)
Defendant.
)
)

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I, Stephen S. Ho, declare:

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1.

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I am a trial attorney with the Tax Division of the United States Department of

Justice in Washington, D.C.
2.

In that position, I am responsible for representing the interests of the United States

in the above-captioned action.
3.

I am writing this declaration from my own personal knowledge and in support of

Defendant’s Administrative Motion for Leave to File Sur-Reply.

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CASE NO. 3:13-CV-2789-WHO
DECLARATION OF STEPHEN S. HO

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4.

On August 25, 2015, I contacted counsel for Plaintiff Public.Resource.Org to

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inquire whether Plaintiff would stipulate or consent to Defendant’s filing of a sur-reply regarding

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its request for fees on fees. Counsel responded that Plaintiff would not so stipulate or consent.

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Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true
and correct.

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Executed on August 26, 2015 in Washington, D.C.

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/s/ Stephen S. Ho
STEPHEN S. HO

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CASE NO. 3:13-CV-2789-WHO
DECLARATION OF STEPHEN S. HO

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