The opinion
1 R rcO larB kE @R pT a rS r. b C roL wA nR .cK om (C BN 93634) B PrR inIA ciN pa lM D. eB pO utY y N AT ssO isN tan t Attorney General
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PARR BROWN GEE & LOVELESS, P.C. ELIZABETH J. SHAPIRO
101 South 200 East, Suite 700 Deputy Director, Federal Programs Branch
3 Salt Lake City, Utah 84111 ALEXANDRA R. SASLAW (SBN 318610)
Telephone: (801) 532-7840 Trial Attorney
4 United States Department of Justice
CHAD S. PEHRSON (CBN 261829) Civil Division, Federal Programs Branch
5 cpehrson@kba.law P.O. Box 883
KUNZLER BEAN & ADAMSON, P.C. Washington, DC 20044
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4225 Executive Square, Suite 600 Phone: (202) 514-4520
7 La Jolla, California 92037 alexandra.r.saslaw@usdoj.gov
619-371-5511
8 Attorneys for Defendants
Attorneys for Plaintiff
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UNITED STATES DISTRICT COURT
10 NORTHERN DISTRICT OF CALIFORNIA
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12 BIOSCIENCE ADVISORS, INC., Civil Action No. 4:21-CV-0866-HSG
13 Plaintiff, STIPULATION AND ORDER
v. REQUESTING EXTENSION OF TIME
14 TO FILE DEFENDANTS’ MOTION
UNITED STATES SECURITIES AND FOR SUMMARY JUDGMENT &
15 EXCHANGE COMMISSION, et al., MODIFICATION OF OTHER
DEADLINES
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Defendants.
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Plaintiff and Defendants (“parties”), by and through undersigned counsel, hereby submit the
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following Stipulation requesting that the Court enter an order providing for a one-week extension of
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time for Defendants to file their motion for summary judgment, and a corresponding extension of
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the deadlines for Plaintiffs’ response and Defendants’ reply. The parties are not requesting a
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continuance of the hearing on this motion, which is currently scheduled for July 28, 2022.
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In support of this request, the parties state as follows:
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1. Pursuant to the Court’s March 21, 2022 Scheduling Order, ECF No. 46, Defendants’
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motion for summary judgment and the corresponding administrative record are currently due on
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May 17, 2022.
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2. Defendants represent that despite working diligently to prepare the administrative
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record and the motion for summary judgment, Defendants have encountered some delays in
1 drafting the motion for summary judgment due to the variety of claims and the volume of FOIA
2 requests at issue in this litigation. Accordingly, Defendants requested Plaintiff’s consent to stipulate
3 to a one-week extension of Defendants’ deadline to file their motion for summary judgment.
4 Plaintiff has agreed to Defendants’ request as a courtesy.
5 3. The parties have agreed, subject to the Court’s approval, that Defendants’ deadline
6 to file their motion for summary judgment should be extended by one week, to May 24, 2022.
7 4. The parties have also agreed, subject to the Court’s approval, that Plaintiff’s deadline
8 to file their opposition to Defendants’ motion shall be extended to June 22, 2022, and that
9 Defendants’ deadline to file their reply brief shall be extended to July 13, 2022.
10 5. The parties are not presently seeking a continuance of the hearing currently
11 scheduled for July 28, 2022, at 2:00 PM, see Order, ECF No. 53, unless the Court believes that such
12 continuance is necessary or desirable in light of the requested extensions.
13 6. The parties have not previously sought or received an extension of the deadlines set
14 out in the Court’s March 21, 2022 Scheduling Order.
15 For these reasons, the parties hereby stipulate that, subject to this Court’s approval,
16 Defendants shall file the administrative record and their motion for summary judgment by May 24,
17 2022; Plaintiff shall file its opposition by June 22, 2022; and Defendants shall file their reply by July
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IT IS SO STIPULATED THIS 13TH DAY OF MAY 2022:
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KUNZLER BEAN & ADAMSON, PC BRIAN M. BOYNTON
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Principal Deputy Assistant Attorney General
22 /s/ Chad S. Pehrson Civil Division
Chad S. Pehrson
23 KUNZLER BEAN & ADAMSON, P.C. ELIZABETH J. SHAPIRO
4225 Executive Square, Suite 600 Deputy Director, Federal Programs Branch
24 La Jolla, California 92037
619-371-5511 /s/ Alexandra R. Saslaw____
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cpehrson@kba.law ALEXANDRA R. SASLAW
26 Trial Attorney
PARR BROWN GEE & LOVELESS United States Department of Justice
27 Robert S. Clark Civil Division, Federal Programs Branch
1 1 S0 al1 t S Lo aku eth C 2 it0 y0 , UEa tas ht, 8S 4u 1it 1e 1 7 00 P W.O as. h B ino gx t o8 n8 ,3 D C 20044
Telephone: (801) 532-7840 Phone: (202) 514-4520
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rclark@parrbrown.com alexandra.r.saslaw@usdoj.gov
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Attorneys for Plaintiff Attorneys for Defendants
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1 ORDER
2 Pursuant to Stipulation, it is ORDERED that:
3 1. Defendant shall file the Administrative Record and Motion for Summary Judgment on
4 or before May 24, 2022;
5 2. Plaintiff shall file its Opposition on or before June 22, 2022; and
° 3. Defendant shall file its Reply on or before July 13, 2022.
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8 Dated: 5/16/2022 Aspe 3 bl) °
9 HAYWOOD S. GILLIAM, JR.
10 United States District Judge
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1 DECLARATION PURSUANT TO LOCAL RULE 5-1(i)(3)
2 Pursuant to Local Rule 5-1(i)(3), the undersigned filer declares that concurrence in the filing
3 of this document has been obtained from the other signatory to this document.
4 I declare under penalty of perjury that the foregoing is true and correct. Executed this 13th
day of May, 2022.
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6 /s/ Alexandra R. Saslaw___
ALEXANDRA R. SASLAW
7 Trial Attorney
United States Department of Justice
Civil Division, Federal Programs Branch
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P.O. Box 883
Washington, DC 20044
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Phone: (202) 514-4520
alexandra.r.saslaw@usdoj.gov
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