Filed: Jun. 09, 2014
Latest Update: Jun. 09, 2014
Summary: STIPULATION AND [PROPOSED] ORDER TO REOPEN THE CASE AND SET A CASE MANAGEMENT CONFERENCE DONNA M. RYU, Magistrate Judge. Plaintiff Gonzales & Gonzales Bonds and Insurance Agency, Inc. ("G&G" or "Plaintiff") and Defendant United States Department of Homeland Security ("DHS"), by and through their respective counsel, make the following representations and stipulate and agree as follows: The parties hereby jointly request that the Court reopen this case and allow Plaintiff to file a Second
Summary: STIPULATION AND [PROPOSED] ORDER TO REOPEN THE CASE AND SET A CASE MANAGEMENT CONFERENCE DONNA M. RYU, Magistrate Judge. Plaintiff Gonzales & Gonzales Bonds and Insurance Agency, Inc. ("G&G" or "Plaintiff") and Defendant United States Department of Homeland Security ("DHS"), by and through their respective counsel, make the following representations and stipulate and agree as follows: The parties hereby jointly request that the Court reopen this case and allow Plaintiff to file a Second ..
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STIPULATION AND [PROPOSED] ORDER TO REOPEN THE CASE AND SET A CASE MANAGEMENT CONFERENCE
DONNA M. RYU, Magistrate Judge.
Plaintiff Gonzales & Gonzales Bonds and Insurance Agency, Inc. ("G&G" or "Plaintiff") and Defendant United States Department of Homeland Security ("DHS"), by and through their respective counsel, make the following representations and stipulate and agree as follows:
The parties hereby jointly request that the Court reopen this case and allow Plaintiff to file a Second Amended Complaint within thirty (30) days of entry of this order. The Second Amended Complaint will relate to the existing five hundred and seventy-one (571) Alien Files ("A-Files") at issue in this litigation and will not seek to include additional A-Files. Nothing herein shall constitute a waiver of Plaintiff's right to seek disclosure under the FOIA of A-Files not included in this litigation.
The parties hereby agree and stipulate that Defendant will have thirty (30) days from the filing of the Second Amended Complaint to file its response.
The parties hereby also agree and stipulate to utilize a sampling of fifty (50) of the five hundred and seventy-one (571) A-Files at issue in this litigation for purposes of cross-motions for summary judgment. The parties have been and will continue to meet and confer on the selection of the fifty (50) A-Files for the sampling. Any decision on the merits of the sample will apply to all of the A-Files at issue in this case.
The parties respectfully request that the Court set a case management conference in this case for August 27, 2014, at 1:30 p.m. The parties will file a joint case management conference statement by August 20, 2014. The statement will inform the Court if the parties have agreed on the procedure for selecting the fifty (50) A-Files for the sampling and, if not, the parties' respective positions on the selection process.
[PROPOSED] ORDER
Pursuant to stipulation by the parties, the Court orders that this case is reopened.
Plaintiff will have thirty (30) days to file a Second Amended Complaint in this action. Defendant will then have thirty (30) days from the filing of the amended complaint to file a response. The next case management conference will be on August 27, 2014 at 1:30 p.m. before the Honorable Donna M. Ryu. The parties are required to file a joint case management conference statement by August 20, 2014.
IT IS SO ORDERED.
