Electronic Frontier Foundation v. Department of Homeland Security

Filing 14

AMENDED STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE re 12 STIPULATION WITH PROPOSED ORDER to Continue Case Management Conference filed by Electronic Frontier Foundation. Joint Case Management Statement due by 3/14/2013. Initial Case Management Conference set for 3/21/2013 02:00 PM. Signed by Judge Phyllis J. Hamilton on 1/29/13. (nah, COURT STAFF) (Filed on 1/29/2013)

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Jennifer Lynch (SBN 240701)
[e-mail]
ELECTRONIC FRONTIER FOUNDATION
454 Shotwell Street
San Francisco, CA 94110
Telephone: [phone]
Facsimile: [phone]
Attorney for Plaintiff
ELECTRONIC FRONTIER FOUNDATION

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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

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Plaintiff,
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v.
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DEPARTMENT OF HOMELAND SECURITY, )
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Defendant.
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ELECTRONIC FRONTIER FOUNDATION,

Case No.: 4:12-cv-5580 PJH
AMENDED
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE
Date: March 7, 2013
Time: 2:00 PM
Place: Courtroom 3, 3rd Floor
Hon. Phyllis J. Hamilton

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC
CASE NO: 12-CV-5580 PJH

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Plaintiff Electronic Frontier Foundation and Defendant Department of Homeland Security

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have conferred and hereby stipulate to and respectfully request the Court continue the initial Case

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Management Conference from its currently scheduled date of March 7, 2013 to March 21, 2013 or

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to the Court’s earliest convenience thereafter.

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Counsel for Plaintiff is scheduled to speak at a conference out of town on March 8, 2013

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and must travel on March 7, 2013. Counsel for Defendant is scheduled to be out of the country on

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vacation on March 14, 2013. March 21, 2013 is the first date that counsel for both parties will be

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available.

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The requested time modification should not adversely affect the Court’s schedule because

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this is a case pursuant to the Freedom of Information Act and the parties have been in

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communications about the agency’s search for records and a possible processing and production

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schedule.

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DATED: January 28, 2013

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Respectfully submitted,
By:

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Attorney for Plaintiff
ELECTRONIC FRONTIER FOUNDATION

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

By:

/s/ Jennie L. Kneedler___
Jennie L. Kneedler, Esq.
United States Trial Attorney
UNITED STATES DEPARTMENT OF JUSTICE
Civil Division, Federal Programs Branch
P.O. Box 883
Washington, DC 20044
Telephone: [phone]
Facsimile: [phone]
Attorney for Defendant
UNITED STATES DEPT. OF HOMELAND
SECURITY

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC
CASE NO: 12-CV-5580 PJH

DECLARATION PURSUANT TO L.R. 5.1

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I, Jennifer Lynch, hereby declare that I have obtained Defendant’s concurrence in the filing
of this document from Jennie L. Kneedler, counsel for Defendant.
Executed on January 28, 2013, in San Francisco, California.

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/s/ Jennifer Lynch
Jennifer Lynch

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J. Hami

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D IS T IC T O
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hyllis
Judge P

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NO

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IT IS S

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The Hon. Phyllis J. Hamilton
United StatesRDEREJudge
District D

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1/29/13
Dated: ______________

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S DISTRICT
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PURSUANT TO STIPULATION, IT IS SO ORDERED. The case management conference is
continued to March 21, 2013 at 2:00 p.m.

UNIT
ED

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC
CASE NO: 12-CV-5580 PJH