UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
January 11, 2013
VINCENT A. CEFALU,
ERIC H. HOLDER, JR., U.S. ATTORNEY GENERAL, U.S. DEPARTMENT OF JUSTICE, DEFENDANT,
The opinion of the court was delivered by: Jacqueline S. Corley United States Magistrate Judge
STIPULATION AND PROPOSED ORDER
THE PARTIES THROUGH THEIR ATTORNEYS OF RECORD STIPULATE AS FOLLOWS:
1. On November 26, 2012, the Court issued an order (ECF 49) regarding defendant's motion to compel plaintiff's web-based writings about his employment that directed the parties to meet and confer on the best method for providing identification and authentication of plaintiff's web-based writings.
2. After meeting and conferring as directed by the Court, the parties agree that plaintiff wrote on the website known as www.cleanupatf.org, using three identifiers: (1) Vincent A Cefalu, (2) Doc Holiday, and (3) Iceman.
3. Writings on www.cleauupatf.org by "Vincent A Cefalu" appear with the words "Vincent A Cefalu" and next to the avatar of a badge copied below:
VINCENT A CEFALU
Member Since 20 Jan 2010
4. Writings on www.cleanupatf.org by "Doc Holiday" appear with the words "Doc Holiday" and next to the avatar copied below:
Joined 29-December 09
5. Writings on www.cleanupatf.org by "Iceman" appear with the word "Iceman" and next to the avatar copied below:
Joined 19-October 10
6. None of the writings by plaintiff using the identifiers Vincent A Cefalu, Doc Holiday, or Iceman have been deleted or removed from www.cleanupatf.org by plaintiff and all of plaintiff's writings are available to anyone accessing www.cleanupatf.org.
7. Upon a request made with reasonable notice, plaintiff will provide the electronic version of his writings on www.cleanupatf.org to counsel for the defendant, to the extent the writing is not publicly available on the site. Plaintiff shall undertake reasonable steps to locate said writing.
8. Other than by using the identifiers Vincent A Cefalu, Doc Holiday, or Iceman, plaintiff has not written any writings appearing on www.cleanupatf.org.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
DATED: 1/10/2013 _/s Zahra Karinshak/_______. Attorneys for Plaintiff DATED: 1/10/2013 _/s Jonathan U. Lee/________. 21 22 Attorneys for Defendant
PURSUANT TO STIPULATION, IT IS SO ORDERED.
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