Lyon et al v. U.S. Immigration and Customs Enforcement et al

Filing 140

STIPULATION AND ORDER re 137 STIPULATION WITH PROPOSED ORDER Extending Expert Discovery Cut-Off filed by U.S. Department of Homeland Security, John Sandweg, Timothy S. Aitken, U.S. Immigration and Customs Enforcement, Jeh Charles Johnson. Signed by Judge Edward M. Chen on 1/6/16. (bpf, COURT STAFF) (Filed on 1/6/2016)

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BENJAMIN C. MIZER
Principal Deputy Assistant Attorney General
WILLIAM C. PEACHEY
Director, District Court Section
ELIZABETH J. STEVENS
Assistant Director, District Court Section
KATHERINE J. SHINNERS
JENNIFER A. BOWEN
BRIAN C. WARD
Trial Attorneys, Office of Immigration Litigation
U.S. Department of Justice – Civil Division
P.O. Box 868, Ben Franklin Station
Washington, D.C. 20044
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendants
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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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AUDLEY BARRINGTON LYON, JR., et. al.,
Plaintiffs,

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Case No.: 13-cv-05878 EMC

SECOND JOINT STIPULATION
EXTENDING EXPERT DISCOVERY
CUT-OFF; [PROPOSED] ORDER

v.
UNITED STATES IMMIGRATION AND
CUSTOMS ENFORCEMENT, et. al.,

CLASS ACTION

Defendants.

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The Parties to this action hereby agree to the following and seek an order extending
expert discovery by an additional three (3) days.
The current deadline to complete expert discovery is January 8, 2016. See Dkt. No. 117.
The Parties have been diligently conducting expert discovery and arranged for one final
deposition for Defendants’ rebuttal expert Michael Hackett on January 7, 2016. Unfortunately,
Mr. Hackett has informed Defendants that he is dealing with a family medical crisis and will be
unavailable the week of January 7. However, Mr. Hackett has represented to Defendants that he
will be available the following week on Monday January 11, 2016.

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SECOND JOINT STIPULATION EXTENDING
EXPERT DISCOVERY CUT-OFF
Case No.: 13-cv-05878 EMC

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Accordingly, the parties seek a three (3) day extension of expert discovery to January 11,

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2016. This three-day extension of expert discovery will not affect any of the other current

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deadlines in this case.

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Dated: January 4, 2016

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By: /s/ Julia Harumi Mass
JULIA HARUMI MASS (SBN 189649)
ANGÉLICA SALCEDA (SBN 296152)
MICHAEL T. RISHER (SBN 191627)
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION OF NORTHERN CALIFORNIA
39 Drumm Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
ORRICK, HERRINGTON & SUTCLIFFE LLP
ROBERT P. VARIAN (SBN 107459)
CHARLES J. HA (pro hac vice)
DAVID KEENAN (pro hac vice)
JUDY KWAN (SBN 273930)
ALEXIS YEE-GARCIA (SBN 277204)
405 Howard Street
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
AMERICAN CIVIL LIBERTIES UNION
NATIONAL PRISON PROJECT
CARL TAKEI (SBN 256229)
915 15th Street N.W., 7th Floor
Washington, DC 20005
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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MARC VAN DER HOUT (SBN 80778)
MEGAN SALLOMI (SBN 300580)
180 Sutter Street
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Plaintiffs

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SECOND JOINT STIPULATION EXTENDING
EXPERT DISCOVERY CUT-OFF
Case No.: 13-cv-05878 EMC

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Dated: January 4, 2016

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OFFICE OF IMMIGRATION LITIGATION,
CIVIL DIVISION
U.S. DEPARTMENT OF JUSTICE
BENJAMIN C. MIZER
Principal Deputy Assistant Attorney General

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WILLIAM C. PEACHEY
Director, District Court Section

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ELIZABETH J. STEVENS
Assistant Director, District Court Section

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By: /s/ Brian C. Ward
BRIAN C. WARD
KATHERINE J. SHINNERS
JENNIFER A. BOWEN
Trial Attorneys, District Court Section
P.O Box 868, Ben Franklin Station
Washington, D.C. 20044
Telephone: [phone]
Email: [e-mail]

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Attorneys for Defendants

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I, Brian C. Ward, am the ECF user whose user ID and password are being used to file this
Stipulation. In accordance with Local Rule 5-1(i)(3), I hereby attest that the other signatories
listed here have concurred in the filing of this document.
Dated: January 4, 2016

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By: /s/ Brian C. Ward
BRIAN C. WARD

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S

R NIA

Dated:

DERED

O OR
IT IS S

HONORABLE EDWARD M. CHEN
United States District Judge
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M. Che
Edward
Judge

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ER

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RT

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FO

NO

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January 6, 2016

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UNIT
ED

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

RT
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S DISTRICT
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[PROPOSED] ORDER

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N

OF

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D S T ICT
SECOND JOINTISTIPULATION EXTENDING
R
EXPERT DISCOVERY CUT-OFF
Case No.: 13-cv-05878 EMC