AMERICAN EDUCATIONAL RESEARCH ASSOCIATION, INC. et al v. PUBLIC.RESOURCE.ORG, INC.

Filing 52

Consent MOTION for Order Request for Telephonic Status Conference by PUBLIC.RESOURCE.ORG, INC. (Becker, Matthew)

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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 Filed: May 23, 2014 v. PUBLIC.RESOURCE.ORG, INC., Defendant/Counterclaimant. Defendant-Counterclaimant Public.Resource.Org respectfully requests that the status conference set by the Court to occur at 2:00 p.m. on Thursday, June 11, 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. Pursuant to Local Civil Rule 7(m), Public Resource has conferred with Plaintiffs’ counsel Jonathan Hudis, who stated that Plaintiffs do not oppose Public Resource’s request that the status conference be held telephonically. Dated: June 8, 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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