Electronic Frontier Foundation v. Department of Justice

Filing 18

STIPULATION WITH PROPOSED ORDER re 13 Order, Set Deadlines/Hearings requesting to appear telephonically at case managment conference filed by Department of Justice. (Sowles, Marcia) (Filed on 9/16/2013)

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STUART F. DELERY
Assistant Attorney General
ELIZABETH J. SHAPIRO
Deputy Branch Director
MARCIA K. SOWLES, D.C. Bar No. 36955
Senior Counsel
United States Department of Justice
Civil Division, Federal Programs Branch
P.O. Box 883
Washington, D.C. 20044
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendant

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IN THE UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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OAKLAND DIVISION
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ELECTRONIC FRONTIER FOUNDATION, )
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Plaintiff,
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v.
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DEPARTMENT OF JUSTICE,
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Defendant.
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Case No.: CV 13-2946 PJH
STIPULATION AND [PROPOSED]
ORDER TO APPEAR
TELEPHONICALLY AT CASE
MANAGEMENT CONFERENCE
Date:
Time:
Place:
Judge:

September 26, 2013
2:00 p.m.
Courtroom 3, 3rd Floor
Hon. Phyllis Hamilton

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STIPULATION AND [PROPOSED] ORDER TO APPEAR
TELEPHONICALLY AT CASE MANAGEMENT CONFERENCE
Case No.: 13-cv-2946 PJH

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Plaintiff Electronic Frontier Foundation (“EFF”) and Defendant Department of Justice
have conferred and hereby stipulate to and respectfully request that the Court permit counsel to
appear telephonically at the initial case management conference scheduled for September 26, 2013
in this matter.
Good cause exists for this request. Counsel for Defendant is an attorney for the United
States Department of Justice who works and resides in Washington, D.C. Permitting counsel for
Defendant to appear by telephone will enable the government to conserve resources that would
otherwise be spent on transportation to and from the hearing, and overnight lodging in Oakland,
California. Counsel for Plaintiff works in San Francisco, which is one hour from the Oakland
courthouse. Permitting counsel for Plaintiff to appear by telephone will save counsel the time that
would otherwise be spent traveling to and from the courthouse.
Moreover, this is a case pursuant to the Freedom of Information Act, and the parties have
been in communication about the agency’s search for records and a possible processing and
production schedule. Therefore, the parties expect there to be few areas of disagreement at the case
management conference.

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DATED: September 16, 2013

Respectfully submitted,

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STIPULATION AND [PROPOSED] ORDER TO APPEAR
TELEPHONICALLY AT CASE MANAGEMENT CONFERENCE
Case No.: 13-cv-2946 PJH

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/s/ Jennifer Lynch
ELECTRONIC FRONTIER FOUNDATION
Jennifer Lynch, Esq.
454 Shotwell Street
San Francisco, CA 94110
Telephone: [phone]
Facsimile: [phone]

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Attorney for Plaintiff

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STUART F. DELERY
Assistant Attorney General
ELIZABETH J. SHAPIRO
Deputy Branch Director
/s/ Marcia K. Sowles
Marcia K. Sowles
Senior Counsel
United States Department of Justice
Civil Division, Federal Programs Branch
P.O. Box 883
Washington, D.C. 20044
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Attorneys for Defendant
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DECLARATION PURSUANT TO CIVIL L. R. 5-1(i)(3)
I, Marcia K. Sowles, attest that I have obtained the concurrence of Jennifer Lynch, Counsel
for Plaintiff, in the filing of this document.
Executed on September 16, 2013, in Washington, DC.

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/s/ Marcia K. Sowles
Marcia K. Sowles

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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Dated: ______________
The Hon. Phyllis J. Hamilton
United States District Judge

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STIPULATION AND [PROPOSED] ORDER TO APPEAR
TELEPHONICALLY AT CASE MANAGEMENT CONFERENCE
Case No.: 13-cv-2946 PJH

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CERTIFICATE OF SERVICE

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I hereby certify that on September 16, 2013, I electronically filed the foregoing document

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with the Clerk of the Court, using the CM/ECF system, which will send notification of such filing

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to the counsel of record in this matter who are registered on the CM/ECF system.

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Executed on September 16, 2013, in Washington, DC.

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/s/ Marcia K. Sowlesr
Marcia K. Sowles

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STIPULATION AND [PROPOSED] ORDER TO APPEAR
TELEPHONICALLY AT CASE MANAGEMENT CONFERENCE
Case No.: 13-cv-2946 PJH