Mark Rumold, Jennifer Lynch, ELECTRONIC FRONTIER FOUNDATION, San Francisco, CA, Attorney for Plaintiff, Electronic Frontier Foundation.
MELINDA HAAG, United States Attorney, ALEX G. TSE, Chief Civil Division, VICTORIA CARRADERO, Assistant United States Attorney, San Francisco, CA, Counsel for Defendant.
STIPULATED REQUEST AND [PROPOSED] ORDER FOR CONTINUANCE OF SUMMARY JUDGMENT HEARING DATE
THELTON E. HENDERSON, District Judge.
Plaintiff Electronic Frontier Foundation and Defendant Department of Commerce respectfully submit the following Stipulated Request and Proposed Order continuing the hearing date on the parties' cross-motions for summary judgment until June 10, 2013. Good cause exists for this Stipulated Request as follows:
1. The hearing on the parties' cross-motion was scheduled for May 6, 2013. Due to illness of Defendant's counsel (ECF No. 29) and the Court's own continuance (ECF No. 32), the hearing is currently scheduled for May 20, 2013.
2. Due to a previously scheduled conflict, Plaintiff's counsel is unavailable on May 20, 2013. May 27, 2013 is a federal holiday. Neither Plaintiff's nor Defendant's counsel are available on June 3, 2013.
3. Therefore, the parties stipulate that the hearing date be continued until June 10, 2013.
4. Granting this Stipulated Request will not alter or extend any other dates or deadlines currently pending in this matter.
WHEREFORE, the parties respectfully request that the Court grant this Stipulated Request and continue the hearing date on the parties' cross-motions until June 10, 2013.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
The hearing date for the parties' cross-motions for summary judgment is ...