Case3:08-cv-04373-JSW Document95 Filed07/11/12 Page1 of 5Case4:08-cv-04373-JSW Document96 Filed07/11/12 Page1 of 3
`
`BETH S. BRINKMANN
`Deputy Assistant Attorney General, Civil Division
`JOSEPH H. HUNT
`Director, Federal Programs Branch
`VINCENT M. GARVEY
`Deputy Branch Director
`ANTHONY J. COPPOLINO
`Special Litigation Counsel
`tony.coppolino@usdoj.gov
`MARCIA BERMAN
`Senior Trial Counsel
`U.S. Department of Justice
`Civil Division, Federal Programs Branch
`20 Massachusetts Avenue, NW, Rm. 6102
`Washington, D.C. 20001
`Phone: (202) 514-4782
`Fax: (202) 616-8460
`Attorneys for the Government Defendants
`Sued in their Official Capacity
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`
`Case No. 3:08-cv-04373-JSW
`
`STIPULATION TO EXPEDITE
`MOTION TO STAY
`PROCEEDINGS; [PROPOSED]
`ORDER
`
`Courtroom:
`
`11 – 19th Floor
`
`Judge:
`
`Hon. Jeffrey S. White
`
`)))))))))))))))))))))))))))))
`
`CAROLYN JEWEL, TASH HEPTING,
`GREGORY HICKS, ERIK KNUTZEN, and
`JOICE WALTON,
`
`
`
`Plaintiffs,
`
`v.
`
`NATIONAL SECURITY AGENCY and
`KEITH B. ALEXANDER, its Director in his
`official and personal capacities; MICHAEL V.
`HAYDEN in his personal capacity; the
`UNITED STATES OF AMERICA;
`BARACK OBAMA, President of the United
`States, in his official capacity; GEORGE W.
`BUSH, in his personal capacity; RICHARD B.
`CHENEY, in his personal capacity; DAVID S.
`ADDINGTON, in his personal capacity;
`DEPARTMENT OF JUSTICE and ERIC
`HOLDER, the Attorney General, in his official
`capacity; MICHAEL B. MUKASEY, in his
`personal capacity; ALBERTO R. GONZALES,
`in his personal capacity; JOHN D. ASHCROFT,
`in his personal capacity; JAMES D. CLAPPER,
`Director of National Intelligence, in his official
`capacity; JOHN M. McCONNELL, in his
`personal capacity; JOHN D. NEGROPONTE, in
`his personal capacity,
`
`Defendants.
`
`
`
`Stip. to Expedite Motion to Stay Proceedings
`Jewel, et al. v. National Security Agency, et al., Case No. 08-cv-4373-JSW
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`Case3:08-cv-04373-JSW Document95 Filed07/11/12 Page2 of 5Case4:08-cv-04373-JSW Document96 Filed07/11/12 Page2 of 3
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`THE PARTIES HEREBY STIPULATE, pursuant to Local Rules 6-1(b), 6-2, and 7-12, to
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`expedite the briefing and adjudication of Defendants’ Motion to Stay Proceedings, filed
`
`concurrently herewith. Plaintiff’s partial motion for summary judgment was filed on July 2,
`
`2012. Defendants’ combined cross-dispositive motion and opposition to plaintiffs’ partial
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`motion for summary judgment is currently due on or before August 31, 2012. Without
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`expedition, the earliest that the instant Motion to Stay Proceedings could be noticed for hearing is
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`August 31, 2012, the day that defendants’ opposition/cross-motion is due. The parties therefore
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`stipulate that plaintiffs’ response to Defendants’ Motion to Stay Proceedings be filed on or before
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`July 23, 2012, and that the motion be submitted at that time.
`
`Date: July 11, 2012
`
`Respectfully Submitted,
`
`BETH S. BRINKMANN
`Deputy Assistant Attorney General, Civil Division
`
`JOSEPH H. HUNT
`Director, Federal Programs Branch
`
`VINCENT M. GARVEY
`Deputy Branch Director
`
` s/ Anthony J. Coppolino
`ANTHONY J. COPPOLINO
`Special Litigation Counsel
`
` s/ Marcia Berman
`MARCIA BERMAN
`Senior Trial Counsel
`U.S. Department of Justice
`Civil Division, Federal Programs Branch
`20 Massachusetts Avenue, NW, Rm. 6102
`Washington, D.C. 20001
`Phone: (202) 514-4782—Fax: (202) 616-8460
`
`Attorneys for Defendants
`
` s/ Cindy Cohn
`CINDY COHN (145997)
`cindy@eff.org
`LEE TIEN (148216)
`KURT OPSAHL (191303)
`
`Stip. to Expedite Motion to Stay Proceedings
`Jewel, et al. v. National Security Agency, et al., Case No. 08-cv-4373-JSW
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`Case3:08-cv-04373-JSW Document95 Filed07/11/12 Page5 of 5Case4:08-cv-04373-JSW Document96 Filed07/11/12 Page3 of 3
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`GENERAL ORDER NO. 45(X) CERTIFICATION
`
`I attest that I have obtained Cindy Cohn’s concurrence in the filing of this document.
`
`/s/ Marcia Berman
`MARCIA BERMAN
`
`PURSUANT TO STIPULATION, IT IS ORDERED that plaintiffs’ response to
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`Defendants’ Motion to Stay Proceedings be filed on or before July 23, 2012. It is FURTHER
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`ORDERED that Defendants’ Motion to Stay Proceedings be submitted at that time.
`
`DATED: ___________________
`
`_______________________________________
`Honorable Jeffrey S. White
`United States District Judge
`
`Stip. to Expedite Motion to Stay Proceedings
`Jewel, et al. v. National Security Agency, et al., Case No. 08-cv-4373-JSW
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`July 11, 2012