In re National Security Agency Telecommunications Records Litigation

Filing 709

STIPULATION re 702 Order, to Extend Time to Submit Joint Status Report by Seema Ahmad, Center for Constitutional Rights, Tina M. Foster, Gitanjali S. Gutierrez, Maria LaHood, Rachel Meeropol. (Kadidal, Shayana) (Filed on 2/25/2010)

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1 2 3 4 5 6 7 8 9 10 hayana Kadidal CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012-2317 Phone: (212) 614-6438 Fax: (212) 614-6499 Email: kadidal@ccr-ny.org Attorney for Plaintiffs Anthony J. Coppolino Special Litigation Counsel UNITED STATES 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 Email: tony.coppolino@usdoj.gov Attorney for Defendants 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 By Order dated January 20, 2010 (dkt. 702 in M:06-cv-1791, dkt. 31 in 3:07-cv-1115), this Court ordered the parties to submit "on or before February 26, 2010, a joint status report advising the court of the status of this case, what proceedings are necessary to resolve it and proposing a tentative schedule for such proceedings." Plaintiffs and Defendants, through counsel, hereby submit this revised stipulation to extend the time for submission of the requested joint status report and proposed schedule to March 19, 2010, and request that the Court make this stipulation an order of the Court. RECITALS | IN RE NATIONAL SECURITY AGENCY | TELECOMMUNICATIONS RECORDS | LITIGATION | _______________________________________| | This Document Relates Only to: | Center for Constitutional Rights v. Bush, | (Case No. 07-1115) | _______________________________________| No. M:06-cv-01791-VRW REVISED STIPULATION TO EXTEND TIME TO SUBMIT JOINT STATUS REPORT; PROPOSED ORDER Chief Judge Vaughn R. Walker UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION S 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 The enlargement of time is necessary to accommodate other litigation burdens on Plaintiffs' counsel, particularly a variety of pre- and post-oral argument responsibilities in Holder v. Humanitarian Law Project, Nos. 08-1498, 09-89, to be argued at the Supreme Court on February 23, 2010, and supplemental and reply briefing in Kiyemba v. Obama, No. 08-1234, to be argued at the Supreme Court on March 23, 2010. As a result of these burdens, counsel for the parties originally stipulated an enlargement of time to March 9, 2010, by stipulation filed February 18, 2010 (dkt. 32 in 3:07-cv-1115). Since that time, counsel for both parties have experienced unanticipated time constraints. Counsel for Plaintiffs has had to make an emergency trip to travel internationally for a week to Albania to deal with the transfer of a Libyan national Guantanamo client who the government has resettled there, beginning this Friday, February 25, 2010. (Counsel for plaintiffs did not have prior notice from the Defense Department of the date of that client's transfer, and thus could not plan around it.) Counsel for the Defendants will be unavailable on March 8-10, 2010 because of the need to assist in the health care of a family member. Because this court has not yet entered the previously-stipulated proposed order for enlargement of time, there have been no previous time modifications relating to the aforementioned Order of January 20, 2010. No prejudice will result from the requested enlargement of time and, as there are no further deadlines scheduled in the case, it will not affect the schedule for the case. REVISED STIPULATION Plaintiffs and Defendants, through counsel, hereby stipulate that the time for submission of the requested joint status report and proposed schedule be enlarged through March 19, 2010, and request that the Court make this stipulation an order of the Court. Respectfully submitted, By: /s/Shayana Kadidal Shayana Kadidal Michael Ratner CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012-2317 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 February 25, 2010 Phone: (212) 614-6438 -- Fax: (212) 614-6499 Email: kadidal@ccrjustice.org David Cole (CCR Cooperating Counsel) c/o Georgetown University Law Center 600 New Jersey Avenue, N.W. Washington, D.C. 20001 (202) 662-9078 Michael Avery J. Ashlee Albies NATIONAL LAWYERS GUILD c/o Suffolk Law School 120 Tremont Street Boston, MA 02108 (617) 573-8551 Attorneys for Plaintiffs MICHAEL F. HERTZ Deputy Assistant Attorney General JOSEPH H. HUNT Director, Federal Programs Branch VINCENT M. GARVEY Deputy Branch Director By: /s/Anthony J. Coppolino Anthony J. Coppolino Special Litigation Counsel UNITED STATES 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 Email: tony.coppolino@usdoj.gov Attorneys for Defendants 3 1 2 3 4 DECLARATION PURSUANT TO GENERAL ORDER 45, X.B I, SHAYANA KADIDAL, hereby declare pursuant to General Order 45, X.B, that I have obtained the concurrence in the filing of this document from the other signatory listed below. I declare under penalty of perjury that the foregoing declaration is true and correct. 5 Executed on February 25, 2010, in the City of New York, New York. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 /s/Shayana Kadidal Shayana Kadidal Michael Ratner CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012-2317 (212) 614-6438 Email: kadidal@ccrjustice.org ANTHONY J. COPPOLINO Special Litigation Counsel UNITED STATES 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 Email: tony.coppolino@usdoj.gov By: /s/ Anthony J. Coppolino per G.O. 45 Attorney for Defendants 4 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 DATE: ____________ NITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION | IN RE NATIONAL SECURITY AGENCY | TELECOMMUNICATIONS RECORDS | LITIGATION | _______________________________________| | This Document Relates Only to: | Center for Constitutional Rights v. Bush, | (Case No. 07-1115) | _______________________________________| No. M:06-cv-01791-VRW Judge: Hon. Vaughn R. Walker [PROPOSED] ORDER The stipulation for an enlargement of time to submit the joint status report and proposed schedule previously ordered by the Court, see Order dated January 20, 2010 (Dkt. 702), shall be and hereby is GRANTED, and the required joint status report and proposed schedule shall be due by no later than March 19, 2010. PURSUANT TO STIPULATION, IT IS SO ORDERED, _______________________________ Chief Judge Vaughn R. Walker U 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 Dated: February 25, 2010 Certificate of Service I, Shayana Kadidal, certify that on February 25, 2010 (PDT), I caused the foregoing Stipulation to be filed electronically on the ECF system and served via email on the counsel for defendants listed below. Anthony J. Coppolino Special Litigation Counsel United States Department of Justice Civil Division, Federal Programs Branch P.O. Box 883 Washington, D.C. 20044 Email: tony.coppolino@usdoj.gov /s/ Shayana Kadidal CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012-2317

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