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American Civil Liberties Union of Northern California v. Fed. Bureau of Investigation

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
Jan 11, 2012
Case No. 3:10-cv-03759-RS (N.D. Cal. Jan. 11, 2012)

Opinion

Case No. 3:10-cv-03759-RS

01-11-2012

THE AMERICAN CIVIL LIBERTIES UNION OF NORTHERN CALIFORNIA, ASIAN LAW CAUCUS, SAN FRANCISCO BAY GUARDIAN Plaintiffs, v. FEDERAL BUREAU OF INVESTIGATION, DEPARTMENT OF JUSTICE, 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


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


Summaries of

American Civil Liberties Union of Northern California v. Fed. Bureau of Investigation

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
Jan 11, 2012
Case No. 3:10-cv-03759-RS (N.D. Cal. Jan. 11, 2012)
Case details for

American Civil Liberties Union of Northern California v. Fed. Bureau of Investigation

Case Details

Full title:THE AMERICAN CIVIL LIBERTIES UNION OF NORTHERN CALIFORNIA, ASIAN LAW…

Court:UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

Date published: Jan 11, 2012

Citations

Case No. 3:10-cv-03759-RS (N.D. Cal. Jan. 11, 2012)