IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA San Francisco Division
August 19, 2011
UNITED STATES DEPARTMENT OF
ENERGY AND NATIONAL NUCLEAR SECURITY ADMINISTRATION, AN AGENCY
OF THE U.S. DEPARTMENT OF ENERGY, DEFENDANTS.
The opinion of the court was delivered by: Honorable Richard Seeborg United States District Judge
SCOTT YUNDT (CSB #242595)
TRI-VALLEY CARES 2582 Old First Street
Livermore, California 94550 Telephone: (925) 443-7148 Facsimile: (925) 443-0177 Email: firstname.lastname@example.org Attorneys for Plaintiff MELINDA HAAG, CSBN 132612 United States Attorney JOANN M. SWANSON, CSBN 88143 Chief, Civil Division
ABRAHAM A. SIMMONS, CSBN 146400 Assistant United States Attorney
450 Golden Gate Avenue, Box 36055 San Francisco, California 94102 Telephone: (415) 436-7124 FAX: (415) 436-7169 Email: email@example.com Attorneys for Federal Defendants
JOINT STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE
INITIAL CASE MANAGEMENT CONFERENCE
Plaintiff Tri-Valley CAREs, Defendant United States Department of Energy, et. al ., by and through their respective counsel, hereby stipulate as follows: WHEREAS, pursuant to the Clerk's Notice filed August 9, 2011, the further Case Management Conference in the above captioned case was rescheduled to be held on September 8, 2011 at 10:00 a.m. in Courtroom 3 on the 17 th Floor of the United States Courthouse, 450 Golden Gate Avenue, San Francisco; and WHEREAS, the parties agree that Defendants will provide to Plaintiff further responses to certain FOIA requests on or before August 31, 2011; and WHEREAS, Plaintiff and Defendants desire to reschedule this further Case Management Conference in the above captioned case to provide the parties with an additional two weeks to review and discuss the further responses and other outstanding claims before preparing the Joint Case Management Statement.
THEREFORE, IT IS HEREBY STIPULATED AND AGREED by Plaintiffs and Defendants, through their respective counsel of record, as follows:
1. The parties agree and request that the court order that the Case Management Conference in the instant case, originally scheduled to be held on Thursday, September 8, 2011 at 10:00 a.m . in Courtroom 3 on the 17 th Floor of the United States Courthouse, 450 Golden Gate Avenue, San Francisco, shall be rescheduled to Thursday, September 22, 2011 at 10:00 a.m. in that same location.
2. The parties shall file a Joint Case Management Statement at least one week prior to the Conference.
3. The parties are close to settlement; the parties request a stay of the briefing schedule until the schedule can be reset at the September 22, 2011 Case Management Conference.
4. The foregoing agreement is not intended, and may not be cited by any party, as admission of any issue of fact or law in this or any other judicial or administrative proceeding.
Scott J. Yundt Abraham Simmons Attorney for Plaintiff Attorney for Defendants Pursuant to General Order No. 45, Section X(B) regarding signatures, I attest under penalty of perjury that concurrence in the filing of this document has been obtained from Abraham Simmons.
Dated this 19th day of August, 2011
Scott J. Yundt
Attorney for Plaintiff
1. The Case Management Conference in the instant case, originally
scheduled to be held on
September 8, 2011 at 10:00 a.m . in Courtroom 3 on the
17 th Floor of the United States
Courthouse, 450 Golden Gate Avenue, San Francisco, shall
be rescheduled to September 22,
2011 at 10:00 a.m. in that same location.
IT IS SO ORDERED.
Presented by: Scott Yundt (CSB# 242595) Attorney for Plaintiffs
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