Opinion
Case No. 3:10-cv-03759-RS
01-11-2012
SOMNATH RAJ CHATTERJEE (CA SBN 177019) ANGELA E. KLEINE (CA SBN 255643) MORRISON & FOERSTER llp JULIA HARUMI MASS (CA SBN 189649) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF NORTHERN CALIFORNIA, INC. NASRINA BARGZIE (CA SBN 238917) ASIAN LAW CAUCUS Attorneys for Plaintiffs IAN HEATH GERSHENGORN Assistant Attorney General JOHN R. TYLER Assistant Branch Director TAMARA ULRICH Trial Attorney U.S. Department of Justice Attorneys for Defendants
SOMNATH RAJ CHATTERJEE (CA SBN 177019)
ANGELA E. KLEINE (CA SBN 255643)
MORRISON & FOERSTER llp
JULIA HARUMI MASS (CA SBN 189649)
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION OF NORTHERN
CALIFORNIA, INC.
NASRINA BARGZIE (CA SBN 238917)
ASIAN LAW CAUCUS
Attorneys for Plaintiffs
IAN HEATH GERSHENGORN
Assistant Attorney General
JOHN R. TYLER
Assistant Branch Director
TAMARA ULRICH
Trial Attorney
U.S. Department of Justice
Attorneys for Defendants
JOINT STIPULATION AND [PROPOSED] ORDER REGARDING DOCUMENT PRODUCTION SCHEDULE
Judge: Hon. Laurel Beeler
WHEREAS in April 2011, Defendant agreed to produce all non-exempt documents responsive to Plaintiffs' March 9, 2010 and July 27, 2011 FOIA Requests (the "FOIA Requests") by December 13, 2011 [ECF No. 56];
WHEREAS Defendant identified approximately 30,000 pages of additional responsive documents in the summer of 2011 [ECF No. 69];
WHEREAS the parties met and conferred regarding the schedule for the production of documents and the method for discussing Defendant's claimed exemptions and conferred with Magistrate Judge Laurel Beeler on November 3, 2011 [ECF Nos. 72, 77], and agreed upon a schedule for the FBI's production of documents in response to the FOIA requests;
WHEREAS, per the parties' agreement, as to responsive documents Defendant identified by May 26, 2011, in accordance with the Court's April 13, 2011 Order and Defendant's May 26, 2011 Notice Regarding Production Schedule [ECF Nos. 56, 61, 63], the FBI produced all non-exempt documents by December 13, 2011; and
WHEREAS, the parties agreed that as to responsive documents Defendant identified after May 26, 2011, Defendant shall process a minimum of 2,500 pages per month in response to the FOIA Requests and shall produce all non-exempt documents by June 30, 2012.
IT IS HEREBY AGREED AND STIPULATED THAT:
1. As to responsive documents Defendant identified after May 26, 2011, Defendant shall process a minimum of 2,500 pages per month in response to the FOIA Requests and shall produce all non-exempt documents by June 30, 2012.
2. The parties will submit a confidential joint letter regarding the method for discussing Defendant's claimed exemptions and contact the courtroom deputy to set a further telephonic settlement conference, per the Court's January 4, 2012 Order
(ECF No. 82).
By: __________
TAMARA ULRICH
IAN HEATH GERSHENGORN
Assistant Attorney General
JOHN R. TYLER
Assistant Branch Director
TAMARA ULRICH
Trial Attorney
U.S. Department of Justice
Civil Division, Federal Programs Branc
20 Massachusetts Avenue, NW
Washington, D.C. 20530
Telephone: 202.305.1432
Fax: 202.616.8470
Email: Tamara.Ulrich@usdoj.gov
Attorneys for Defendants
FEDERAL BUREAU OF
INVESTIGATIONS, DEPARTMENT OF
JUSTICE
By: __________
ANGELA E. KLEINE
SOMNATH RAJ CHATTERJEE
(CA SBN 177019)
SChatterjee@mofo.com
ANGELA E. KLEINE (CA SBN 255643)
AKleine@mofo.com
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105
Telephone: 415.268.7000
Facsimile: 415.268.7200
JULIA HARUMI MASS (CA SBN 189649)
JMass@aclunc.org
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION OF NORTHERN
CALIFORNIA, INC.
39 Drumm Street
San Francisco, California 94111
Telephone: 415.621.2493
Facsimile: 415.255.8437
NASRINA BARGZIE (CA SBN 238917)
NasrinaB@asianlawcaucus.org
ASIAN LAW CAUCUS
55 Columbus Avenue
San Francisco, California 94111
Telephone: 415.896.1701
Facsimile: 415.896.1702
Attorneys for Plaintiffs
THE AMERICAN CIVIL LIBERTIES UNION
OF NORTHERN CALIFORNIA, ASIAN LAW
CAUCUS, AND THE SAN FRANCISCO BAY
GUARDIAN
[PROPOSED] ORDER
Having reviewed the parties' joint stipulation, and for good cause ___
It is so ORDERED this 11 day of January, 2012.
______________
The Honorable Laurel Beeler
United States Magistrate Judge
ATTESTATION OF E-FILED SIGNATURE
I, Angela E. Kleine, am the ECF User whose ID and Password are being used to file this Joint Stipulation and [Proposed] Order Regarding Document Production Schedule. In compliance with General Order 45, X.B., I hereby attest that Julia Harumi Mass, Nasrina Bargzie and Tamara Ulrich have concurred in this filing.
By: Angela E. Kleine