Google Inc. et al v. Egger et al

Filing 294

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Google Inc. et al v. Egger et al Doc. 294 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PETER D. KEISLER Assistant Attorney General, Civil Division CARL J. NICHOLS Deputy Assistant Attorney General DOUGLAS N. LETTER Terrorism Litigation Counsel JOSEPH H. HUNT Director, Federal Programs Branch ANTHONY J. COPPOLINO Special Litigation Counsel RUPA BHATTACHARYYA Senior Trial Counsel ANDREW H. TANNENBAUM Trial Attorney Email: tony.coppolino@usdoj.gov U.S. Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Avenue, NW, Rm. 6102 Washington, D.C. 20001 Phone: (202) 514-4782 Fax: (202) 616-8460 Attorneys for the United States of America and the Federal Defendants in their Official Capacities UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) ) ) ) ) _______________________________________) ) ) This Document Relates Only To: ) ) Shubert v. Bush, ) (Case No. 07-00693) _______________________________________) IN RE NATIONAL SECURITY AGENCY TELECOMMUNICATIONS RECORDS LITIGATION No. M:06-cv-01791-VRW DEFENDANTS' ADMINISTRATIVE MOTION TO EXTEND PAGE LIMITS IN CONNECTION WITH DEFENDANTS' MOTION TO DISMISS OR FOR SUMMARY JUDGMENT Date: Courtroom: Time: Judge: August 30, 2007 6, 17th Floor 2 p.m. Hon. Vaughn R. Walker The United States and the official capacity Defendants, through their undersigned counsel, hereby move, pursuant to Civil L.R. 7-11, for an order enlarging the page limit for (1) the public Memorandum in Support of the State Secrets Privilege and Motion to Dismiss or For Summary Judgement by the United States and the Official Capacity Defendants, up to and including a total of 40 pages; and (2) the classified Memorandum in Support of the State Secrets Privilege and Motion to Dismiss or For Summary Judgement by the United States and the MDL No. M:06-CV-01791-VRW and Shubert v. Bush (07-CV-00693-VRW) DEFENDANTS' ADMINISTRATIVE MOTION TO EXTEND PAGE LIMITS IN CONNECTION WITH DEFENDANTS' MOTION TO DISMISS OR FOR SUMMARY JUDGMENT Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Official Capacity Defendants that has been lodged for the Court's in camera, ex parte review, for the length of that memorandum. The additional pages beyond the 25 page limit for each memorandum are needed in order to inform the Court fully of the grounds supporting dismissal of this matter based on the assertion of the military and state secrets privilege and other specified statutory privileges. Plaintiffs do not oppose the request to extend the page limits as to the publicly filed memorandum so long as, in turn, Plaintiffs are allowed up to 60 pages for any brief in opposition. The United States and official capacity Defendants do not object to allowing Plaintiffs up to 60 pages for their opposition brief. A proposed order is attached hereto. DATED: May 25, 2007 Respectfully Submitted, PETER D. KEISLER Assistant Attorney General, Civil Division CARL J. NICHOLS Deputy Assistant Attorney General DOUGLAS N. LETTER Terrorism Litigation Counsel JOSEPH H. HUNT Director, Federal Programs Branch /s/ Anthony J. Coppolino ANTHONY J. COPPOLINO Special Litigation Counsel /s/ Rupa Bhattacharyya RUPA BHATTACHARYYA Senior Trial Counsel /s/ Andrew H. Tannenbaum ANDREW H. TANNENBAUM Trial Attorney U.S. Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Avenue, NW Washington, D.C. 20001 Phone: (202) 514-4782 -- Fax: (202) 616-8460 Email: tony.coppolino@usdoj.gov MDL No. M:06-CV-01791-VRW and Shubert v. Bush (07-CV-00693-VRW) DEFENDANTS' ADMINISTRATIVE MOTION TO EXTEND PAGE LIMITS IN CONNECTION WITH DEFENDANTS' MOTION TO DISMISS OR FOR SUMMARY JUDGMENT 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MDL No. M:06-CV-01791-VRW and Shubert v. Bush (07-CV-00693-VRW) [PROPOSED] ORDER GRANTING DEFENDANTS' MOTION TO EXTEND PAGE LIMITS UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) ) ) ) ) _______________________________________) ) This Document Relates Only To: ) ) Shubert v. Bush, ) (Case No. 07-00693) ) _______________________________________) IN RE NATIONAL SECURITY AGENCY TELECOMMUNICATIONS RECORDS LITIGATION No. M:06-cv-01791-VRW [PROPOSED] ORDER GRANTING DEFENDANTS' MOTION TO EXTEND PAGE LIMITS IN CONNECTION WITH DEFENDANTS' MOTION TO DISMISS OR, IN THE ALTERNATIVE, FOR SUMMARY JUDGMENT Judge: Hon. Vaughn R. Walker [PROPOSED] ORDER Upon consideration of the administrative motion of the United States and the official capacity Defendants to extend page limits in connection with Defendants' Motion to Dismiss or, in the Alternative, for Summary Judgment, the record of this case, and good cause appearing, it is HEREBY ORDERED THAT Defendants' motion to extend page limits shall be and hereby is GRANTED; and it is FURTHER ORDERED THAT the page limit for the public Memorandum in Support of the State Secrets Privilege and Motion to Dismiss or For Summary Judgement by the United States and the Official Capacity Defendants shall be and is hereby extended to up to 40 pages; and it is FURTHER ORDERED THAT the page limit for the classified Memorandum in Support of the State Secrets Privilege and Motion to Dismiss or For Summary Judgement by the United States and the Official Capacity Defendants, submitted for the Court's in camera, ex parte review, shall be and is hereby extended to the length of that memorandum; and it is 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 FURTHER ORDERED THAT the page limit for the Plaintiffs' Opposition to the Defendants' Motion to Dismiss or, in the Alternative, for Summary Judgment, shall be and hereby is extended to up to 60 pages. SO ORDERED: DATE: _______________ _____________________________ The Honorable Vaughn R. Walker Chief Judge, United States District Court Northern District of California MDL No. M:06-CV-01791-VRW and Shubert v. Bush (07-CV-00693-VRW) [PROPOSED] ORDER GRANTING DEFENDANTS' MOTION TO EXTEND PAGE LIMITS 2

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