BR 14-01 Government's Response to Motion to Correct the Record (FISC 2014)
Annotate this Case
Download PDF
UNITED STATES FOREIGN INTELLIGENCE SURVEILLANCE cou~~ 111 litR 13 p;; 12: l 8 WASHINGTON, D.C. IN RE APPLICATION OF THE FEDERAL BUREAU OF INVESTIGATION FOR AN ORDER REQUIRING THE PRODUCTION OF TANGIBLE THINGS Docket No. BR 14-01 RESPONSE OF 'F,iE UNITED STATES OF AMERICA TO THE MOTION OF PLAINTIFFS IN JEWEL V. NSA AND FIRST UNITARIAN CHURCH V. NSA, BOTH PENDING IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA, FOR LEAVE TO CORRECT THE RECORD Movants, plaintiffs in litigation pending in the United States District Court for the Northern District of California, Jewel v. NSA, No. C-08-4373-JSW ("Jewef'), and First Unitarian Church ofLos Angeles v. NSA, No. 3:13-cv-03287-JSW, have filed a Motion ("Mot.") in this Court seeking leave to submit two preservation orders and other materials filed in Jewel and a companion case, Shubert v. Obama, No. C-07-0693-JSW C'Shuben") (also pending in the Northern District of California). The United States does not object to Movants' introduction of these materials into the record of this proceeding. However, as Movants acknowledge, Mot. at 3, and as this Court has recognized, issues regarding the Government's compliance with "prior preservation orders issued by the Northern District of California" are "a matter for the District Court to resolve." March 12, 2014 Opinion and Order at 4 n.3. 1 Dated: March 12, 2014 Respectfully submitted, J!\.cting Assistant Attorney General National Security Division Stuart F. Delery Assistant Attorney General Civil Division United States Department of Justice 1 Contrary to their representation, see Mot. at 1, Movants did not make a "specific request" that the Government inform this Court about the preservation orders in Jewel and Shubert. See Government's March 11, 2014 Notice and Motion, Ex. A (attaching Declaration of Cindy Cohn, Ex. E). In any event, as this Court is aware, litigation is now ongoing in the Northern District of California concerning preservation obligations in the Jewel and Shubert matters. 2 CERTIFICATE OF SERVICE I hereby certify that, on March 13, 2014, a true and correct copy of the Response of the United States of America to the Motion of Plaintiffs in Jewel v. NSA and First Unitarian Church v. NSA for Leave to Correct the Record was submitted, by hand delivery, to a Litigation Security Officer, for delivery to the following counsel of record for Movants: KURT OPSAHL Electronic Frontier Foundation 815 Eddy Street San Francisco, California 94109 Telephone: (415) 436-9333 Counsel for Movants Plaintiffs in Jewel v. NSA, No. 08-cv-4373-JSW (N.D. Cal.) and First Unitarian Church v. NSA, No. 13-cv-3287-JSW (N.D. Cal.) Matthew'Th..airiza National Sec 'rl Division U.S. Department of Justice
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.
