The Center for Investigative Reporting (CIR) v. Department of Homeland Security

Filing 16

STIPULATION AND ORDER re 15 . STIPULATION WITH PROPOSED ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE filed by The Center for Investigative Reporting (CIR), United States Department of Homeland Security. Case Management Statement due by 4/10/2018. Initial Case Management Conference set for 4/17/2018 01:30 PM in Oakland, Courtroom 4, 3rd Floor. Signed by Magistrate Judge Kandis A. Westmore on 3/22/18. (sisS, COURT STAFF) (Filed on 3/22/2018)

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D. Victoria Baranetsky SBN #311892
THE CENTER FOR INVESTIGATIVE REPORTING
1400 65th St., Suite 200
Emeryville, CA 94608
Telephone: [phone]
Fax: [phone]
[e-mail]

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Attorney for Plaintiff
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David A. Pereda (CABN 237982)
Assistant United States Attorney
1301 Clay Street, Suite 340S
Oakland, CA 94612
Telephone: [phone]
FAX: [phone]
[e-mail]
Attorney for Federal Defendant

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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THE CENTER FOR INVESTIGATIVE
REPORTING,

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Plaintiff,
v.
UNITED STATES DEPARTMENT OF
HOMELAND SECURITY,
Defendant.

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CASE NO. 4:18-CV-00044-KAW
JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE

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Whereas, counsel for plaintiff The Center for Investigative Reporting will be at a preplanned event as a speaker at a law school;
Whereas the parties wish to further meet and confer to narrow the issues in this case; and

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-1JOINT STIPULATION AND [PROPOSED] ORDER

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Whereas all parties who have appeared in this case have consented to adjust certain dates
and deadlines in this case in order to accommodate the schedule.
Pursuant to Local Civil Rule 6-2, the parties who have appeared in this case stipulate as

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follows:
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1) The Case Management Conference is currently scheduled for April 3, 2018.

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2) Subject to the Court’s approval, we respectfully request that the Court continue

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the Initial Case Management Conference to April 17, 2018 at 1:30 pm, or

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another available date at the Court’s convenience.

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3) The last day to meet and confer, file Rule 26(f) Report, complete initial
disclosures or state objection in Rule 26(f) Report and file Case Management

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Statement shall be April 10, 2018.
4) This change is necessary because it raises a conflict for plaintiff’s and

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defendant’s counsel was unavailable in this case and parties require more time to

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meet and confer.

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5) All counsel have agreed to this change.

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DATED: March 22, 2018

By: /s/ D. Victoria Baranetsky
D. Victoria Baranetsky SBN #311892
THE CENTER FOR INVESTIGATIVE REPORTING
1400 65th St., Suite 200
Emeryville, CA 94608
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff

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-2JOINT STIPULATION AND [PROPOSED] ORDER

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By: **/s/ David Pereda

DATED: March 22, 2018

David Pereda
Assistant United States Attorney

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Attorney for Defendant

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** THE ELECTRONIC SIGNATORY OBTAINED APPROVAL FROM THIS SIGNATORY.

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[PROPOSED] ORDER

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Based on the Joint Stipulation of the parties, and good cause appearing therefore, IT IS ORDERED

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that the CASE MANAGEMENT CONFERENCE currently set for April 3, 2018 be and hereby is

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continued to 4/17/18. Statement due 4/10/18.IT IS SO ORDERED.
______________________.

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3/22/18
DATED: __________________.

By:

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HONORABLE KANDIS A. WESTMORE
UNITED STATES MAGISTRATE JUDGE

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-3-

JOINT STIPULATION AND [PROPOSED] ORDER