Sai v. Smith et al

Filing 201

STIPULATION AND ORDER re 200 STIPULATION WITH PROPOSED ORDER Re Protective Order Briefing Schedule filed by Kirstjen Nielsen. Signed by Judge Jon S. Tigar on June 29, 2018. (wsn, COURT STAFF) (Filed on 6/29/2018)

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1 ALEX G. TSE (CABN 152348) Acting United States Attorney 2 SARA WINSLOW (DCBN 457643) Chief, Civil Division 3 WENDY M. GARBERS (CABN 213208) Assistant United States Attorney 4 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102-3495 5 Telephone: (415) 436-6475 FAX: (415) 436-7234 6 wendy.garbers@usdoj.gov 7 Attorneys for Defendant SECRETARY OF THE 8 DEPARTMENT OF HOMELAND SECURITY 9 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 SAN FRANCISCO DIVISION 13 SAI, 14 15 16 17 18 ) ) Plaintiff, ) ) v. ) ) COVENANT AVIATION SECURITY, LLC, et ) al., ) Defendants. ) ) No. 16-cv-01024 JST STIPULATION AND [PROPOSED] ORDER RE PROTECTIVE ORDER BRIEFING SCHEDULE The Honorable Jon S. Tigar 19 20 WHEREAS, the parties’ proposed protective orders and briefs concerning same are currently due 21 today (ECF 173, 199), with responding briefs due on July 13, 2018 (id.); 22 WHEREAS, this morning, Sai asked Defendants if they would stipulate to continue the schedule. 23 Sai indicated that Sai is in very severe health; 24 WHEREAS, Defendants had previously offered Sai this accommodation prior to Sai’s filing a 25 motion to amend the briefing schedule, but Sai declined it (ECF 187-2 at 14-15); 26 WHEREAS, Defendants are prepared to file their protective order papers today, but agree to 27 extend the schedule as an accommodation to Sai; 28 30 IT IS HEREBY STIPULATED, by Plaintiff, the Secretary of the Department of Homeland STIPULATION AND [PROPOSED] ORDER RE PROTECTIVE ORDER BRIEFING SCHEDULE No. 16-cv-01024 JST 1 1 Security, and Covenant Aviation Security, LLC, that, subject to Court approval, the parties must file their 2 competing proposed protective orders by July 6, 2018. Responding briefs are due by July 20, 2018. 3 4 DATED: June 29, 2018 Respectfully submitted, 5 ALEX G. TSE Acting United States Attorney 6 /s/ Wendy M. Garbers WENDY M. GARBERS Assistant United States Attorney 7 8 9 DATED: June 29, 2018 CODDINGTON, HICKS & DANFORTH 10 11 /s/ Richard G. Grotch* RICHARD G. GROTCH 12 13 Attorneys for Defendant COVENANT AVIATION SECURITY, LLC 14 15 16 DATED: June 29, 2018 PLAINTIFF SAI 17 /s/ Sai * SAI Plaintiff Pro Se 18 19 20 *In compliance with Civil Local Rule 5-1(i)(3), the filer of this document attests under penalty of 21 perjury that all signatories have concurred in the filing of this document. 22 [PROPOSED]DISTRI ORDER United States District Judge R NIA ER STIPULATION AND [PROPOSED] ORDER RE PROTECTIVE ORDER BRIEFING SCHEDULE C N F No. 16-cv-01024 JST O D A H 30 FO Ti ga r e Jon S. Jud JON S. TIGAR HONORABLEg RT 28 ERED O ORD IT IS S NO 27 Dated: June 29, 2018 LI 26 CT C PURSUANT TO STIPULATION, IT IS SO ORDERED. UNIT ED 25 ES AT T RT U O 24 S 23 IS T RIC T 2

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