In re National Security Agency Telecommunications Records Litigation

Filing 725

STIPULATION and REQUEST to Extend and Modify Briefing Schedule in Center for Constitutional Rights et al v. Obama et al (07-cv-1115-VRW) by United States. (Coppolino, Anthony) (Filed on 4/22/2010) Modified on 4/26/2010 (far, COURT STAFF).

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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 MICHAEL F. HERTZ Deputy Assistant Attorney General JOSEPH H. HUNT Director, Federal Programs Branch VINCENT M. GARVEY Deputy Branch Director ANTHONY J. COPPOLINO Special Litigation Counsel tony.coppolino@usdoj.gov U.S. Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Avenue, N.W. Washington, D.C. 20001 Phone: (202) 514-4782 Fax: (202) 616-8460 Attorneys for Defendants Shayana Kadidal Michael Ratner CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012-2317 (212) 614-6438 Email: kadidal@ccrjustice.org Attorneys for Plaintiffs UNITED 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, et al. v. Barack Obama, et al. (07-cv-1115-VRW) ) _______________________________________) No. M:06-cv-01791-VRW STIPULATION AND REQUEST TO EXTEND AND MODIFY BRIEFING SCHEDULE Chief Judge Vaughn R. Walker RECITALS 1. By order dated March 26, 2010 (Dkt. 720), the Court, upon consideration of the parties' joint status report, set a schedule in this action for the submission of cross dispositive motions by the parties under which Government Defendants must renew their dispositive motion by April 28, 2010; plaintiffs must file an opposition to defendants' renewed motion and renew plaintiffs' cross-motion for summary judgment by May 28, 2010; defendants must reply and file Stipulation and Request to Extend and Modify Briefing Schedule; Proposed Order Center for Constitutional Rights, et al. v. Barack Obama, et al. (07-CV-1115-VRW) (M:06-CV-1791-VRW) 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 an opposition to plaintiffs' cross-motion by June 18, 2010; and plaintiffs may file a cross-reply by July 9, 2010. 2. Subsequently, on March 31, 2010 and April 19, 2010, the Court issued orders in Al-Haramain Islamic Foundation of Oregon, Inc. et al. v. Obama, et al. (07-cv-00109-VRW), under which the Government Defendants in that action would have submissions to the Court due on April 30, 2010 and May 21, 2010. See Dkts. 721 at 45 and 724 at 1. These deadlines were not in place when the Government stipulated to a briefing schedule in the CCR action. 3. Accordingly, at the request of the Government Defendants, the parties in the CCR action have stipulated to a revised briefing schedule and seek the Court's approval for that revised schedule. 4. No hearing date has been scheduled in connection with the parties' forthcoming submissions in this action and, thus, no change to any date on the Court's calendar would be necessary if the briefing schedule is revised. STIPULATION The parties, through their undersigned counsel, hereby stipulate and agree to the following revised briefing schedule in this action: (i) the Government Defendants must renew their dispositive motion by May 27, 2010; (ii) plaintiffs must file an opposition to defendants' renewed motion and renew plaintiffs' cross-motion for summary judgment by June 24, 2010; (iii) defendants must reply and file an opposition to plaintiffs' cross-motion by July 15, 2010; and (iv) plaintiffs may file a cross-reply by August 5, 2010. A proposed order is attached hereto. Respectfully Submitted, For Government Defendants' Position MICHAEL F. HERTZ Deputy Assistant Attorney General JOSEPH H. HUNT Director, Federal Programs Branch VINCENT M. GARVEY Deputy Branch Director For Plaintiffs' Position Shayana Kadidal Michael Ratner CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012-2317 Stipulation and Request to Extend and Modify Briefing Schedule; Proposed Order Center for Constitutional Rights, et al. v. Barack Obama, et al. (07-CV-1115-VRW) (M:06-CV-1791-VRW) 1 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 ANTHONY J. COPPOLINO Special Litigation Counsel tony.coppolino@usdoj.gov U.S. Department of Justice, Civil Division20 Massachusetts Avenue, N.W. Washington, D.C. 20001 Phone: (202) 514-4782 By: s/ Anthony J. Coppolino ANTHONY J. COPPOLINO Attorneys for Defendants (212) 614-6438 Email: kadidal@ccrjustice.org By: s/ Shayana Kadidal per G.O. 45 SHAYANA KADIDAL Attorneys for Plaintiffs Stipulation and Request to Extend and Modify Briefing Schedule; Proposed Order Center for Constitutional Rights, et al. v. Barack Obama, et al. (07-CV-1115-VRW) (M:06-CV-1791-VRW) 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 DECLARATION PURSUANT TO GENERAL ORDER 45, X.B I, ANTHONY J. COPPOLINO, 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 above (Shayana Kadidal, Attorney for Plaintiffs). I declare under penalty of perjury that the foregoing declaration is true and correct. Executed on April 22, 2010, in the City of Washington, D.C. 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 Attorney for Defendants Stipulation and Request to Extend and Modify Briefing Schedule; Proposed Order Center for Constitutional Rights, et al. v. Barack Obama, et al. (07-CV-1115-VRW) (M:06-CV-1791-VRW) 3 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 Stipulation and Request to Extend and Modify Briefing Schedule; Proposed Order Center for Constitutional Rights, et al. v. Barack Obama, et al. (07-CV-1115-VRW) (M:06-CV-1791-VRW) 4 UNITED 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, et al. ) v. Barack Obama, et al. (07-cv-1115-VRW) ) _______________________________________) No. M:06-cv-01791-VRW [PROPOSED] ORDER Chief Judge Vaughn R. Walker Upon consideration of the parties' stipulation and request to extend and modify the current briefing schedule in this action, and good cause appearing, the Court hereby revises the current briefing schedule set forth in the Court's Order of March 26, 2010 (Dkt. 720) as follows: the Court ORDERS that the parties renew their respective cross-motions according to the following briefing schedule: (i) the Government Defendants must renew their dispositive motion by May 27, 2010; (ii) plaintiffs must file an opposition to defendants' renewed motion and renew plaintiffs' cross-motion for summary judgment by June 24, 2010; (iii) defendants must reply and file an opposition to plaintiffs' cross-motion by July 15, 2010; and (iv) plaintiffs may file a cross-reply by August 5, 2010. PURSUANT TO STIPULATION, IT IS SO ORDERED, DATE: ____________ _______________________________ Chief Judge Vaughn R. Walker

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