UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION
December 6, 2010
VIETNAM VETERANS OF AMERICA, ET AL.,
CENTRAL INTELLIGENCE AGENCY, ET AL.,
The opinion of the court was delivered by: The Honorable Elizabeth D. Laporte Magistrate Judge, United States District Court for the Northern District of California
STIPULATION AND [PROPOSED] ORDER ENLARGING TIME FOR SETTLEMENT PROPOSAL
Complaint filed January 7, 2009 subject to the Court's consideration and approval, as follows:
Pursuant to Civil Local Rules 6-2 and 7-12, the parties hereby respectfully stipulate,
1. On October 29, 2010, the Court ordered that "Plaintiffs shall provide to Defendants a written proposal regarding notice, secrecy oath and principles for provision of 5 health care and adjudication, no later than thirty days from today." (Doc. 174.); proposal is currently due on November 29, 2010.*fn1 (See Declaration of Timothy W. Blakely in Decl."), ¶ 2.) weekend, and the individual and organizational Plaintiffs need additional time to confer regarding 12 the settlement proposal. (Id. at ¶ 3.) a written proposal regarding notice, secrecy oath and principles for provision of health care and 15 adjudication. (Id. at ¶ 3.) conferred by telephone regarding a proposed extension to the current schedule. (Id. at ¶ 4.)
2. Pursuant to the Court's October 29, 2010 Order, Plaintiffs' settlement Support of Stipulation and [Proposed] Order Enlarging Time for Settlement Proposal ("Blakely 9
3. The current deadline falls immediately after the Thanksgiving Holiday
4. Plaintiffs request fourteen (14) additional days to provide Defendants with
5. On November 22, 2010 counsel for Plaintiffs and Defendants met and
6. The parties agree to a brief fourteen-day extension of the November 29, 2010 deadline so that Plaintiffs may have until December 13, 2010 to provide Defendants a 20 written proposal regarding notice, secrecy oath and principles for provision of health care and 21 adjudication. (Id. ¶ 5.) 22 23 related exchange is not submitted for the purpose of delay. The stipulated continuance reflects 24 the parties' good-faith and reasonable attempt to accommodate Plaintiffs' request for additional 25 time in light of the holiday. (Id. at ¶ 6.) 26
IT IS SO STIPULATED.
Dated: November 24, 2010
GORDON P. ERSPAMER TIMOTHY W. BLAKELY STACEY M. SPRENKEL DANIEL J. VECCHIO DIANA LUO MORRISON & FOERSTER LLP By: /s/ TIMOTHY W. BLAKELY Timothy W. Blakely [firstname.lastname@example.org] Attorneys for Plaintiffs Dated: November 24, 2010 IAN GERSHENGORN 10 Deputy Assistant Attorney General JOSEPH P. RUSSONIELLO United States Attorney VINCENT M. GARVEY Deputy Branch Director JOSHUA E. GARDNER Trial Attorney KIMBERLY L. HERB Trial Attorney UNITED STATES DEPARTMENT OF JUSTICE CIVIL DIVISION FEDERAL PROGRAMS BRANCH By: /s/ JOSHUA E. GARDNER Joshua E. Gardner [email@example.com] Attorneys for Defendants
PURSUANT TO STIPULATION, IT IS SO ORDERED.
GENERAL ORDER 45 ATTESTATION
I, Timothy W. Blakely, am the ECF User filing this Stipulation Regarding Confidential Settlement Discussions. In compliance with General Order 45, X.B., I hereby attest that Joshua E. Gardner has concurred in this filing.
Dated: November 24, 2010
/s/ TIMOTHY W. BLAKELY Timothy W. Blakely Attorneys for Plaintiffs