American Civil Liberties Union Foundation et al v. United States Immigration and Customs Enforcement

STIP. TO CONTINUE CMC; DECL.; [PROPOSED] ORDER
CASE NO. 3:22-CV-7534-TSH
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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.
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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
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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
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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
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[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