AMERICAN EDUCATIONAL RESEARCH ASSOCIATION, INC. et al v. PUBLIC.RESOURCE.ORG, INC.
Filing
48
NOTICE Consent Request for Telephonic Status Conference [Dkt. No. 45] by PUBLIC.RESOURCE.ORG, INC. re Set/Reset Hearings, (Becker, Matthew)
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN EDUCATIONAL RESEARCH
ASSOCIATION, INC., AMERICAN
PSYCHOLOGICAL ASSOCIATION, INC., and
NATIONAL COUNCIL ON MEASUREMENT IN
EDUCATION, INC.,
Plaintiffs/Counter-defendants,
Case No. 1:14-cv-00857-TSC-DAR
CONSENT REQUEST FOR TELEPHONIC
STATUS CONFERENCE [DKT. NO. 45]
Filed:
May 23, 2014
v.
PUBLIC.RESOURCE.ORG, INC.,
Defendant/Counterclaimant.
Defendant-Counterclaimant Public.Resource.Org respectfully requests that the status
conference requested by Plaintiffs (Dkt. No. 45) and ordered by the Court to occur at 2:00 p.m.
on Thursday, May 21, 2015 be held telephonically, or in the alternative, allow for a telephonic
appearance by Public Resource’s counsel. As a one-person California non-profit with limited
resources and pro bono representation, Public Resource has incurred great expense for repeated
travel across the country and lodging in the District of Columbia, including travel for previously
scheduled conferences.
Public Resource understands the Court’s need to manage its calendar, and the Court’s
preference for in-person conferences. In this case, however, Public Resource believes a
telephonic conference is appropriate, because a telephonic status conference or appearance
would not impair discussion of any outstanding issues. The principal purpose stated in Plaintiffs’
request for a status conference (Dkt. No. 45) was to discuss the joint consent motion to extend
time for discovery (Dkt. No. 42) which has subsequently been granted by the Court, and to
discuss Plaintiffs’ motion to compel discovery (Dkt. No. 27), which has already been fully
argued before the Court.
Pursuant to Local Civil Rule 7(m), Public Resource has conferred with Plaintiffs’ counsel
Katherine Cappaert, who stated that Plaintiffs do not oppose Public Resource’s request that the
status conference be held telephonically.
Dated: May 19, 2015
Respectfully submitted,
/s/ Matthew B. Becker
Andrew P. Bridges (admitted)
abridges@fenwick.com
Matthew B. Becker (pro hac vice)
mbecker@fenwick.com
FENWICK & WEST LLP
555 California Street, 12th Floor
San Francisco, CA 94104
Telephone: (415) 875-2300
Facsimile: (415) 281-1350
David Halperin (D.C. Bar No. 426078)
davidhalperindc@gmail.com
1530 P Street NW
Washington, DC 20005
Telephone: (202) 905-3434
Mitchell L. Stoltz (D.C. Bar No. 978149)
mitch@eff.org
Corynne McSherry (pro hac vice)
corynne@eff.org
ELECTRONIC FRONTIER FOUNDATION
815 Eddy Street
San Francisco, CA 94109
Telephone: (415) 436-9333
Facsimile: (415) 436-9993
Attorneys for Defendant-Counterclaimant
Public.Resource.Org, Inc.
2
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