Freedom of the Press Foundation v. United States Department of Justice

Northern District of California, cand-4:2015-cv-03503

ORDER Granting {{33}} STIPULATION to Exceed Page Limit. Signed by Judge Haywood S. Gilliam, Jr. on 6/3/2016.

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1 Marcia Hofmann (SBN 250087) Zeitgeist Law PC 2 25 Taylor St. San Francisco, CA 94102 3 marcia@zeitgeist.law Telephone: (415) 830-6664 4 Ahmed Ghappour (SBN 255723) 5 200 McAllister St. San Francisco, CA 96102 6 ghappour@uchastings.edu Telephone: (415) 598-8605 7 Attorneys for Plaintiff 8 FREEDOM OF THE PRESS FOUNDATION 9 10 UNITED STATES DISTRICT COURT 11 FOR THE NORTHERN DISTRICT OF CALIFORNIA 12 SAN FRANCISCO DIVISION 13 FREEDOM OF THE PRESS FOUNDATION,) Civil Action No. 3:15-cv-03503-HSG) 14 Plaintiff,) STIPULATION TO EXCEED PAGE) LIMIT AND ORDER 15 v.)) 16) UNITED STATES DEPARTMENT OF) 17 JUSTICE,)) 18 Defendant.)) 19 20 PLAINTIFF FREEDOM OF THE PRESS FOUNDATION AND DEFENDANT UNITED 21 STATES DEPARTMENT OF JUSTICE HEREBY STIPULATE, pursuant to Local Rules 7-4(b) 22 and 7-12, that the page limit for plaintiff's opposition to defendant's motion for summary judgment 23 and cross-motion for summary judgment, due June 10, 2016, is extended to 40 pages, and 24 defendant's opposition to the cross-motion for summary judgment and reply in support of its 25 motion for summary judgment, due July 1, 2016, is extended to 30 pages. 26 In support of this stipulation, the parties state the following: 27 1. Plaintiff's opposition to defendant's motion for summary judgment and cross-motion 28 for summary judgment is due on June 10, 2016. In that filing, plaintiff anticipates -1- STIPULATION TO EXCEED PAGE LIMIT 1 opposing several exemptions claimed by the government to protect various documents 2 from disclosure under the Freedom of Information Act, 5 U.S.C. § 552. The parties 3 have agreed to extend the page limit for this filing from 25 pages to 40 pages, given the 4 number of redactions plaintiff intends to dispute and legal issues to be briefed. 5 2. Defendant's opposition to the cross-motion for summary judgment and reply in support 6 of its motion for summary judgment is due July 1, 2016. The parties have agreed to 7 extend the page limit for this filing from 25 pages to 30 pages, given the number of 8 redactions likely to be in dispute and legal issues to be briefed, as well as the proposed 9 extension for the plaintiff's June 10 filing. 10 3. Due to the foregoing circumstances, the parties respectfully request the forgoing 11 extensions of the 25-page limit for opposition papers set forth in Local Rule 7-4(b). 12 13 Respectfully submitted, 14 15 DATED: June 1, 2016 /s/ Marcia Hofmann Marcia Hofmann 16 Zeitgeist Law PC 25 Taylor St. 17 San Francisco, CA 94102 Telephone: (415) 830-6664 18 Ahmed Ghappour 19 200 McAllister St. San Francisco, CA 94102 20 Telephone: (415) 598-8605 21 Attorneys for Plaintiff FREEDOM OF THE PRESS FOUNDATION 22 23 24 LOCAL RULE 5-1(i) ATTESTATION 25 I attest that I have obtained Andrew Bernie's concurrence in the filing of this document. 26 27 /s/ Marcia Hofmann 28 -2- STIPULATION TO EXCEED PAGE LIMIT 1 ORDER 2 3 PURSUANT TO STIPULATION, IT IS ORDERED that the page limit for plaintiff's opposition 4 brief and cross-motion for summary judgment to be filed June 10, 2016 is extended to 40 pages. It 5 is FURTHER ORDERED that the page limit for defendant's opposition brief and reply to be filed 6 July 1, 2016 is extended to 30 pages. 7 8 DATED: June 3, 2016 ________________________________________ HON. HAYWOOD S. GILLIAM JR. 9 United States District Judge 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3- STIPULATION TO EXCEED PAGE LIMIT