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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 26, 2013

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

The opinion of the court was delivered by: United States District Judge Hon. Susan Ilston

JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE ) CASE MANAGEMENT CONFERENCE

Date: March 8, 2013 Time: 3:00 p.m. Courtroom: 10, 19th Floor Judge: Hon. Susan Illston

2 hereby stipulate to and respectfully request that this Court continue the date of the Case 3

Management Conference from March 8, 2013 to March 22, 2013, or to the Court's earliest 4 convenience thereafter. The reason for this request is that Jason Schultz, counsel for Plaintiff, is on 5 paternity leave and Jennifer Lynch, also counsel for Plaintiff, is traveling March 8 and 15, 2013. 6

7 the parties are actively working to develop a schedule for resolving the case. 8 9

Plaintiff Electronic Frontier Foundation and Defendants Department of Defense, et al.

The requested time modification should not adversely affect the Court's schedule because

DATED: February 22, 2013 Respectfully submitted, 10 ELECTRONIC FRONTIER FOUNDATION Assistant Attorney General Jennifer Lynch, Esq. 12 454 Shotwell Street JOSEPH P. RUSSONIELLO San Francisco, CA 94110 United States Attorney 13 Telephone: (415) 436-9333 Facsimile: (415) 436-9993 JOHN TYLER 14 E-mail: jlynch@eff.org Assistant Branch Director 15 SAMUELSON LAW, TECHNOLOGY & Kimberly L. Herb 17 PUBLIC POLICY CLINIC Trial Attorney United Stated Department of Justice UC Berkeley School of Law Civil Division, Federal Programs Branch 18 396 Simon Hall 20 Massachusetts Ave. NW Berkeley, CA 94720-7200 Washington, DC 20530 19 Telephone: (510) 642-0499 Telephone: (202) 305-8356 Facsimile: (510) 643-4625 Facsimile: (202) 616-8470 20 E-mail: jschultz@law.berkeley.edu E-mail: Kimberly.L.Herb@usdoj.gov 21 Attorneys for Plaintiff Attorneys for Defendants 22 23 24 25 26 27 /s/ Jennifer Lynch TONY WEST 11 Jason M. Schultz Lilia I. Bailey /s/ Kimberly L. Herb 16

CIVIL LOCAL RULE 5-1 CERTIFICATION

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

/s/ Jennifer Lynch Jennifer Lynch

PURSUANT TO STIPULATION, IT IS SO ORDERED. 2 3

20130226

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