MHP [PROPOSED] STIPULATION RE CASE MANAGEMENT CONFERENCE DATE Date: October 19, 2009 Time: 2:00 p.m. Court: 15, 18th Floor
STIPULATION RE CASE MANAGEMENT CONFERENCE Case No. C-07- 4997-MHP Plaintiff, the Center for Biological Diversity (the "Center"), and defendant, the Office of Management and Budget ("OMB"), by and through their undersigned counsel, hereby submit the following Proposed Stipulation Re Case Management Conference Date.
As this Court is aware, OMB recently located additional documents responsive to the Center's FOIA request that have not been submitted for in camera inspection to Magistrate Judge Zimmerman.
OMB has released a number of these documents to the Center, and the parties are presently engaged in discussions about some additional documents OMB may release to the Center, whether other documents are subject to the Court's summary judgment rulings, whether all remaining documents should be released to the Center, or whether they should be submitted for in camera inspection. The parties are hopeful that the matter can be resolved between themselves, and thus request that the date on which the Center must file any request for immediate release of the remaining documents, the date of any response by OMB, and the date of the next Case Management Conference, be delayed by two weeks.
Subject to the Court's approval, the parties stipulate and have agreed that (1) the Center shall have until October 27, 2009 at 4:00 p.m. to file any request for immediate release of the remaining, recently located documents; (2) OMB shall have until October 29, 2009 at 4:00 p.m. to file a responsive brief, if any; and (3) the next Case Management Conference take place on November 2, 2009 at 3:00 p.m.
Dated: October 16, 2009 JOSEPH P. RUSSONIELLO MICHAEL T. PYLE Assistant United States Attorney Attorney for Defendant OMB VERA PARDEE Attorney for Plaintiff Center for Biological Diversity
As stipulated by the parties, (1) the Center for Biological Diversity shall file any briefing to request the immediate release of the recently discovered documents by October 27, 2009 at 4:00 p.m.; (3) OMB shall file any responsive briefing by October 29, 2009 at 4:00 p.m.; and (2) the next Case Management Conference in this matter shall take place on November 2, 2009 at 3:00 p.m.
© 1992-2009 VersusLaw ...