MELINDA HAAG, (CSBN 132612) United States Attorney, ALEX G. TSE, (CSBN 152348) Chief, Civil Division, MARK R. CONRAD, (CSBN 255667) Assistant United States Attorney, San Francisco, California, Attorneys for Defendants.
Scott J. Yundt, (CSBN 242595) TRI-VALLEY CARES, Livermore, California, Attorney for Plaintiff.
STIPULATION CONTINUING CASE MANAGEMENT CONFERENCE AND FURTHER EXTENDING TIME FOR FEDERAL DEFENDANTS TO RESPOND TO COMPLAINT
ELIZABETH D. LAPORTE, Magistrate Judge.
WHEREAS, on June 7, 2013, Plaintiff Tri-Valley CARES ("Plaintiff") filed its complaint in the above-captioned matter against Defendant United States Department of Energy ("DOE") and Defendant National Nuclear Security Administration ("NNSA") in connection with alleged violations of the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, see Dkt. No. 1;
WHEREAS, since the filing of the Complaint, Defendants have furnished partial or complete responses to each of the FOIA requests referenced in the Complaint and are continuing to review, redact, and produce documents in response to certain of these requests;
WHEREAS, the parties have previously stipulated to extend the deadline for Defendants to respond to the Complaint in this matter, and Defendants have not yet answered the Complaint, see Dkt. Nos. 11 & 14;
WHEREAS, on September 3, 2013, an initial case management conference was held in this matter, at which time the Court continued the hearing for approximately sixty (60) days until November 19, 2013, so that Defendants could continue their review and production of documents related to Plaintiff's requests, see Dkt. No. 16;
WHEREAS, on November 12, 2013, pursuant to the stipulation of the parties, the Court again continued the initial case management conference for approximately sixty (60) days until January 28, 2014, so that Defendants could continue their review and production of documents related to Plaintiff's requests, see Dkt. No. 18;
WHEREAS, in light of the volume and sensitivity of the documents called for by the five FOIA requests referenced in the Complaint, undersigned counsel for Plaintiff and Defendants are engaged in ongoing meet-and-confer discussions about Defendants' responses to the FOIA requests and are seeking to minimize the issues that will need to be decided by the Court;
NOW, THEREFORE, in light of the parties' ongoing meet-and-confer efforts, and pursuant to Civil L.R. 6-1(a), Plaintiff and Defendants stipulate that the Case Management Conference scheduled for January 28, 2014, shall be continued until April 1, 2014, at 10:00 a.m., and that the deadline for Defendants to respond to the Complaint in this matter shall be, and hereby is, extended until and including April 8, 2014.
IT IS SO STIPULATED.
Pursuant to the stipulation of the parties, the Case Management Conference scheduled in this matter for January 28, 2014, is hereby CONTINUED until April 1, 2014, at 10:00 a.m. The deadline for Defendants to respond to the ...