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)
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
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Telephone: (415) 436-6475
FAX: (415) 436-7234
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wendy.garbers@usdoj.gov
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Attorneys for Defendant SECRETARY OF THE
8 DEPARTMENT OF HOMELAND SECURITY
9
10
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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15
16
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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;
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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);
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WHEREAS, Defendants are prepared to file their protective order papers today, but agree to
27 extend the schedule as an accommodation to Sai;
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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
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/s/ Wendy M. Garbers
WENDY M. GARBERS
Assistant United States Attorney
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DATED: June 29, 2018
CODDINGTON, HICKS & DANFORTH
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/s/ Richard G. Grotch*
RICHARD G. GROTCH
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Attorneys for Defendant
COVENANT AVIATION
SECURITY, LLC
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DATED: June 29, 2018
PLAINTIFF SAI
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/s/ Sai *
SAI
Plaintiff Pro Se
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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.
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[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
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FO
Ti ga r
e Jon S.
Jud JON S. TIGAR
HONORABLEg
RT
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ERED
O ORD
IT IS S
NO
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Dated: June 29, 2018
LI
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CT
C
PURSUANT TO STIPULATION, IT IS SO ORDERED.
UNIT
ED
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ES
AT
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S
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IS T RIC T
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