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-07534Cand22 janv. 2026
Texte intégral
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 CRAIG H. MISSAKIAN (CABN 125202) United States Attorney PAMELA T. JOHANN (CABN 145558) Chief, Civil Division KENNETH BRAKEBILL (CABN 196696) Assistant United States Attorney 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102-3495 Telephone: (415) 436-7167 FAX: (415) 436-6748 kenneth.brakebill@usdoj.gov Attorneys for Defendant 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; DECLARATION 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 January 29, 2026, see ECF No. 65, and all associated deadlines, until March 5, 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. In light of the government shut down and the accompanying furlough status of Defendant’s counsel, as well as the extended medical leave of Defendant’s counsel, resolution of the matter has been delayed. However, counsel for Defendant just returned to work from leave, counsel for the parties are meeting and conferring on attorney’s fees and Case 3:22-cv-07534-TSH Document 67 Filed 01/22/26 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 costs, and the parties believe that an approximate 30 day continuance of the Case Management Conference to March 5, 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-second 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: January 22, 2026 /s/ Andrew S. Ong ANDREW S. ONG GOODWIN PROCTER LLP Attorneys for Plaintiffs Respectfully submitted, CRAIG H. MISSAKIAN United States Attorney /s/ Kenneth Brakebill1 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 67 Filed 01/22/26 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 KENNETH BRAKEBILL I, Kenneth Brakebill, declare as follows: 1. I am an Assistant United States Attorney and the attorney of record for Defendant 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 March 5, 2026, to provide additional time for the parties to meet and confer about Plaintiffs’ claim for attorney’s fees and costs in an attempt to resolve this issue without the need for Court intervention. 3. I just returned to work after an extended medical leave, have begun meeting and conferring with Plaintiff’s counsel on attorney’s fees issues, and the parties agree that an approximate 30-day extension of the Case Management Conference will enable the parties to attempt to resolve the attorney’s fees issue. 4. This is the parties’ twenty-second joint request to modify the schedule for this matter. The parties previously stipulated to extend the answer deadline and the Case Management Conference eighteen times. See ECF Nos. 16, 21-36, 38-39, 40-41, 42-43, 45-56, 58-59, 61-62, 64-65. 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 22nd day of January, 2026, in San Francisco, California. /s/ Kenneth W. Brakebill KENNETH W. BRAKEBILL Assistant United States Attorney Case 3:22-cv-07534-TSH Document 67 Filed 01/22/26 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 March 5, 2026, at 10:00 a.m. A joint case management statement is due one week prior. DATED: January 22, 2026 THE HON. THOMAS S. HIXSON United States Magistrate Judge Case 3:22-cv-07534-TSH Document 67 Filed 01/22/26 Page 4 of 4
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