DAVID J. BERGER, State Bar
No. 147645 THOMAS J. MARTIN, State Bar No. 150039 CATHERINE E. MORENO, State Bar
No. 264517 WILSON SONSINI GOODRICH & ROSATI, Professional Corporation, Palo
PAUL CHAVEZ, State Bar No. 241576 LAWYERS' COMMITTEE FOR CIVIL RIGHTS, San Francisco, CA,
JULIA HARUMI MASS, State Bar
No. 189649 ALAN L. SCHLOSSER, State Bar No. 49957 AMERICAN CIVIL LIBERTIES UNION
FOUNDATION OF NORTHERN CALIFORNIA, INC., San Francisco, CA, Attorneys for
Trial Attorney, U.S. Department of Justice, Civil Division, Office of
Immigration Litigation, District Court Section, Washington, DC, STUART F. DELERY, Principal Deputy Assistant Attorney General, DAVID J. KLINE, Director, Office of Immigration Litigation, District Court Section, VICTOR M. LAWRENCE, Assistant Director, SAMUEL P. GO, Senior Litigation Counsel, CHRIS HOLLIS, Trial Attorney Attorneys for Defendants.
JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE SCHEDULE
RICHARD SEEBORG, District Judge.
Pursuant to Civil Local Rules 6-2 and 7-12, the parties respectfully request a modification to the case schedule in this matter in order to permit the parties to attempt to settle this litigation.
WHEREAS, on November 8, 2012, after considering a Joint Case Management Statement submitted by the parties, Judge Seeborg entered an order extending the deadlines for: fact discovery, expert designations, supplemental and rebuttal expert designations, and expert witness discovery (Dkt. Nos. 104, 107);
WHEREAS, on November 28, 2012, the parties participated in a settlement conference before Magistrate Judge Beeler;
WHEREAS, on December 17, 2012, the parties stipulated to extend certain discovery deadlines to allow them to focus their efforts on the production of discovery particularly relevant to settlement (Dkt. Nos. 115, 118);
WHEREAS, on February 25, 2013, and March 11, 2013, the parties participated in further settlement conferences before Magistrate Judge Beeler;
WHEREAS, the parties have held further telephonic settlement conferences since that time, and have made further progress in their attempts to reach a negotiated resolution of this matter; and
WHEREAS, the parties have continued these settlement efforts while also pressing forward with discovery and ...