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Electronic Frontier Foundation v. Department of Defense

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


February 28, 2011

ELECTRONIC FRONTIER FOUNDATION,
PLAINTIFF,
v.
DEPARTMENT OF DEFENSE, ET AL.,
DEFENDANTS.

The opinion of the court was delivered by: Judge: Hon. Susan Illston

STIPULATION AND [PROPOSED] ORDER FOR BRIEFING SCHEDULE

Date: February 25, 2011 Time: 2:30 p.m. Place: Courtroom 10, 19th Floor

This matter came on for a status hearing before the Court on February 25, 2011. In

2 preparation for the status hearing, the parties have conferred and agreed to a procedure intended to 3 streamline the resolution of the remaining issues in this lawsuit. In furtherance of this objective, 4 and with the goal of making the most efficient use of scarce judicial resources, the parties have 5 agreed to the following deadlines in this case. The parties jointly request that the Court adopt the 6 parties' proposed schedule. 7 8

Defendants DHS/ICE complete search and production of all documents. May 25, 2011 9 10

Defendants DHS/ICE provide Plaintiff with a draft Vaughn index and a description of their searches. July 1, 2011 11 12

Plaintiff will inform DHS/ICE of the documents and redactions on which it would like to proceed to summary judgment. August 8, 2011 13 14

Defendants Secret Service, FBI, Criminal Division, DHS, and ICE move for summary judgment and file Vaughn indexes 15 with the Court. September 23, 2011 16

Plaintiff files opposition and cross-moves for summary judgment. October 21, 2011 17

Defendants file reply and opposition to Plaintiff's motion. November 4, 2011 18

Plaintiff files reply in support of motion for summary judgment. November 18, 2011 19

Oral argument. December 9, 2011 20 21 22 23 24 25 26 27 28

Respectfully submitted, 3 4

/s/ Jennifer Lynch TONY WEST 5

ELECTRONIC FRONTIER FOUNDATION Assistant Attorney General Jennifer Lynch, Esq. 6

Marcia Hofmann, Esq. JOHN TYLER 454 Shotwell Street Assistant Branch Director 7

San Francisco, CA 94110 Telephone: (415) 436-9333 /s/ Kimberly Herb 8

Facsimile: (415) 436-9993 Kimberly L. Herb

Trial Attorney

SAMUELSON LAW, TECHNOLOGY United Stated Department of Justice AND PUBLIC POLICY CLINIC Civil Division, Federal Programs Branch 10

Jason M. Schultz 20 Massachusetts Ave. NW U.C. Berkeley School of Law Washington, DC 20530 11

396 Simon Hall Telephone: (202) 305-8356

Facsimile: (202) 616-8470

9

Berkeley, CA 94720-7200 E-mail: Kimberly.L.Herb@usdoj.gov Telephone: (510) 642-0499 13

Facsimile: (510) 643-4625 Attorneys for Defendants 14 15

Attorneys for Plaintiff 16 17

GENERAL ORDER NO. 45(X) CERTIFICATION

I attest that I have obtained Kimberly Herb's concurrence in the filing of this document.

Jennifer Lynch

20

Jennifer Lynch

PURSUANT TO STIPULATION, IT IS SO ORDERED. 22

Dated:2/28/11

Hon. Susan Ilston United States District Judge

20110228

© 1992-2011 VersusLaw Inc.



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