3:22-cv-07534•American Civil Liberties Union Foundation et al v. United States Immigration and Customs Enforcement
American Civil Liberties Union Foundation et al v. United States Immigration and Customs Enforcement
3:22-cv-07534CandDec 1, 2025
Full text
STIP. TO CONTINUE CMC; DECL.; [PROPOSED] ORDER CASE NO. 3:22-CV-7534-TSH 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ANDREW ONG (SBN 267889) AOng@goodwinlaw.com GOODWIN PROCTER LLP 601 Marshall Street Redwood City, California 94063 Tel.: +1 650 752 3100 Fax: +1 650 853 1038 SIDRA MAHFOOZ (Pro Hac Vice) AMERICAN CIVIL LIBERTIES UNION 125 Broad St. New York, NY 10004 Tel.: +1 646 885 8420 smahfooz@aclu.org Attorneys for Plaintiffs MY KHANH NGO (SBN 317817) HANNAH SCHOEN (SBN 332039) AMERICAN CIVIL LIBERTIES UNION 39 Drumm Street San Francisco, CA 94111 Tel.: +1 415 343 0770 mngo@aclu.org hschoen@aclu.org SHILPI AGARWAL (SBN 270749) ACLU FOUNDATION OF NORTHERN CALIFORNIA 39 Drumm Street San Francisco, CA 94111 sagarwal@aclunc.org UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION AMERICAN CIVIL LIBERTIES UNION FOUNDATION; ACLU OF NORTHERN CALIFORNIA, Plaintiffs, v. UNITED STATES IMMIGRATION AND CUSTOMS ENFORCEMENT, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 3:22-CV-07534-TSH JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE Pursuant to Civil Local Rules 6-2 and 7-12, the parties to this action hereby stipulate and request that the Court continue the Case Management Conference currently set for December 4, 2025, see ECF No. 62, and all associated deadlines, until January 29, 2026, at 10:00 a.m. The parties previously agreed that all issues relating to Defendant’s obligation to produce records under FOIA have been resolved, and that the only outstanding unresolved issues relate to Plaintiffs’ claim for attorney’s fees and costs. See ECF No. 55. Plaintiffs have provided Defendant with information Case 3:22-cv-07534-TSH Document 65 Filed 12/01/25 Page 1 of 4
STIP. TO CONTINUE CMC; DECL.; [PROPOSED] ORDER CASE NO. 3:22-CV-7534-TSH 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 regarding their claim for attorney’s fees and costs. In light of the government shut down and furlough status of Defendant’s counsel, as well as the current medical leave of Defendant’s counsel, resolution of the matter has been delayed. The parties, however, believe that the additional time allowed by a continuance of the Case Management Conference to January 29, 2026 will allow them sufficient time to attempt to resolve Plaintiffs’ claim for attorney’s fees and costs without the need for further litigation. This is the parties’ twenty-first request to modify the schedule in this case. The requested modification will not impact the schedule for the case because no further schedule has yet been set. DATED: November 30, 2025 /s/ Andrew S. Ong1 ANDREW S. ONG GOODWIN PROCTER LLP Attorneys for Plaintiffs Respectfully submitted, CRAIG H. MISSAKIAN United States Attorney /s/ Kenneth Brakebill KENNETH BRAKEBILL Assistant United States Attorney Attorneys for Defendant 1 In compliance with Civil Local Rule 5-1(i)(3), the filer of this document attests under penalty of perjury that all signatories have concurred in the filing of this document. Case 3:22-cv-07534-TSH Document 65 Filed 12/01/25 Page 2 of 4
STIP. TO CONTINUE CMC; DECL.; [PROPOSED] ORDER CASE NO. 3:22-CV-7534-TSH 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF ANDREW S. ONG I, Andrew S. Ong, declare as follows: 1. I am a partner at Goodwin Procter LLP and counsel of record for Plaintiffs in this action. I submit this declaration in support of the parties’ Joint Stipulation to Continue the Case Management Conference filed concurrently herewith. The facts set forth in this declaration are within my personal knowledge or based upon documents and information I have received in the course of this litigation. 2. The parties have agreed to request a continuance of the case management conference until January 29, 2026, to provide additional time for the parties to meet and confer about Plaintiffs’ claim for attorney’s fees and costs and continue their discussions to determine whether they have any further disputes and, if so, whether they can be resolved without the need for Court intervention. 3. This additional time accommodates the government shutdown and furlough status of the Defendant’s counsel, as well as Defendant’s counsel’s current medical leave. 4. This is the parties’ twenty-first joint request to modify the schedule for this matter. The parties previously stipulated to extend the answer deadline and the case management conference seventeen times. See ECF Nos. 16, 21-36, 38-39, 40-41, 42-43, 45-56, 58-59, 61-62. 5. The requested continuance of the case management conference will not affect the schedule for the case because no further schedule has yet been set. I declare under penalty of perjury under the laws of the United States that the above is true and accurate to the best of my information, knowledge, and belief. Executed this 30th day of November, 2025, in San Francisco, California. /s/ Andrew S. Ong ANDREW S. ONG Attorney for Plaintiffs Case 3:22-cv-07534-TSH Document 65 Filed 12/01/25 Page 3 of 4
STIP. TO CONTINUE CMC; DECL.; [PROPOSED] ORDER CASE NO. 3:22-CV-7534-TSH 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 [PROPOSED] ORDER Pursuant to stipulation, IT IS SO ORDERED. The Case Management Conference is continued until January 29, 2026, at 10:00 a.m. A joint case management statement is due one week prior. DATED: December 1, 2025 THE HON. THOMAS S. HIXSON United States Magistrate Judge Case 3:22-cv-07534-TSH Document 65 Filed 12/01/25 Page 4 of 4
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