Sai v. Smith et al

Filing 115

STIPULATION AND ORDER re 113 STIPULATION WITH PROPOSED ORDER to Continue CMC filed by Transportation Security Administration (TSA), Department of Homeland Security (DHS), United States of America. Signed by Judge Jon S. Tigar on August 30, 2017. (wsn, COURT STAFF) (Filed on 8/30/2017)

1 BRIAN J. STRETCH (CABN 163973)
United States Attorney
2 SARA WINSLOW (DCBN 457643)
Chief, Civil Division
3 WENDY M. GARBERS (CABN 213208)
Assistant United States Attorney
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450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
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Telephone: [phone]
FAX: [phone]
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[e-mail]
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Attorneys for Defendants UNITED STATES
8 OF AMERICA; DEPARTMENT OF HOMELAND
SECURITY; and TRANSPORTATION
9 SECURITY ADMINISTRATION
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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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SAI,
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Plaintiff,
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v.
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DAVID SMITH, et al.
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Defendants.

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Case No. 16-cv-01024-JST
STIPULATION AND [PROPOSED] ORDER TO
CONTINUE CMC
Current Date: September 13, 2017
Current Time: 2:00 p.m.

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WHEREAS, the initial Case Management Conference (“CMC”) in this matter is currently set for

20 September 13, 2017, at 2:00 p.m.;
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WHEREAS, plaintiff Sai filed plaintiff’s Second Amended Complaint (“SAC”) on August 18,

22 2017, and defendants’ responses are due on September 8, 2017;
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WHEREAS, both the Federal Defendants and defendant Covenant Aviation Security, LLC

24 (“Covenant”) intend to file a motion to dismiss in response to the SAC;
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WHEREAS, defendants submit that it is premature to conduct a Rule 26(f) conference and

26 proceed with discovery until the pleadings are settled;
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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC
16-CV-01024 JST

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IT IS HEREBY STIPULATED, by Plaintiff, the Federal Defendants, and Covenant that, subject to

2 Court approval, the September 13, 2017 CMC herein should be taken off calendar and reset to a time after
3 the pleadings are settled.
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5 DATED: August 30, 2017

Respectfully submitted,

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BRIAN J. STRETCH
United States Attorney

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/s/ Wendy M. Garbers
WENDY M. GARBERS
Assistant United States Attorney

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Attorneys for Defendants UNITED
STATES OF AMERICA;
DEPARTMENT OF HOMELAND
SECURITY; and
TRANSPORTATION SECURITY
ADMINISTRATION

13 DATED: August 30, 2017

CODDINGTON, HICKS & DANFORTH

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/s/ Richard G. Grotch*
RICHARD D. GROTCH

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Attorneys for Defendant
COVENANT AVIATION
SECURITY, LLC

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20 DATED: August 30, 2017

PLAINTIFF SAI

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/s/ Sai *
SAI
Plaintiff Pro Se

24 *In compliance with Civil Local Rule 5-1(i)(3), the filer of this document attests under penalty of
perjury that all signatories have concurred in the filing of this document.
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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC
16-CV-01024 JST

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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4 Dated:

August 30, 2017

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HONORABLE JON S. TIGAR
United States District Judge

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC
16-CV-01024 JST

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