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Electronic Frontier Foundation v. Department of Commerce

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


October 18, 2012

ELECTRONIC FRONTIER FOUNDATION,
PLAINTIFF,
v.
DEPARTMENT OF COMMERCE,

The opinion of the court was delivered by: The Honorable Thelton E. Henderson United States District Court Judge

STIPULATION AND [PROPOSED] ORDER ON SUMMARY JUDGMENT BRIEFING SCHEDULE

Place: Courtroom 12, 19th Floor Defendant. Judge: Hon. Thelton E. Henderson

Plaintiff Electronic Frontier Foundation ("EFF") and Federal Defendant the United States Department of Commerce respectfully submit the stipulation on summary judgment briefing in this 3 matter and request that the Court order the same. 4

Defendant will file its Motion for Summary Judgment on January 21, 2013. Defendant will 5 have 30 pages for its opening brief. 6

Plaintiff will file a combined Opposition to Defendant's Motion/Cross-Motion for Summary Judgment on February 20, 2013. Plaintiff will have 30 pages for its combined 8

Opposition/Cross-Motion. 9

Defendant will file a combined Opposition to Plaintiff's Cross-Motion/Reply brief in 10 support of its motion on March 22, 2013. Defendant will have 30 pages for its combined 11 Opposition/Reply brief. 12

Plaintiff will file a Reply brief in support of its Motion for Summary Judgment on April 5, 2013. Plaintiff will have 15 pages for its reply. 14

The hearing on the parties' Motions for Summary Judgment will be held on April 29, 2013.

Unless the Court feels otherwise, the parties agree to vacate the Case Management Conference currently set for Monday, October 22, 2012. 17

DATED: October 18, 2012 Respectfully submitted, 18 /s/ Mark Rumold ELECTRONIC FRONTIER FOUNDATION Mark Rumold, Esq. 454 Shotwell Street 20 San Francisco, CA 94110 Telephone: (415) 436-9333 21 Facsimile: (415) 436-9993 22 Attorney for Plaintiff MELINDA HAAG United States Attorney 24 ________/s/_____________________ 25 Victoria Carradero 26 Assistant U.S. Attorney 23 Attorneys for Federal Defendant 28 27

DECLARATION PURSUANT TO GENERAL ORDER 45

I, Victoria R. Carradero, attest that I have obtained the concurrence of Mark Rumold, Counsel for Plaintiff, in the filing of this document. 4

Executed on October 18, 2012, in San Francisco, California.

/s/ Victoria R. Carradero

Victoria R. Carradero

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Defendant will file its Motion for Summary Judgment on January 21, 2013. Defendant will 2 have 30 pages for its opening brief. 3

Plaintiff will file a combined Opposition to Defendant's Motion/Cross-Motion for Summary Judgment on February 20, 2013. Plaintiff will have 30 pages for its combined 5 Opposition/Cross-Motion. 6

Defendant will file a combined Opposition to Plaintiff's Cross-Motion/Reply brief in 7 support of its motion on March 22, 2013. Defendant will have 30 pages for its combined 8 Opposition/Reply brief. 9

Plaintiff will file a Reply brief in support of its Motion for Summary Judgment on April 5, 2013. Plaintiff will have 15 pages for its reply. 11

The hearing on the parties' Motions for Summary Judgment will be held on April 29, 2013.

The Case Management Conference currently set for Monday, October 22, 2012 is VACATED.

Henderson R Judge Thelton

20121018

© 1992-2012 VersusLaw Inc.



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