fe fAKEE y ») ‘USDS SDNY lpacr UNITED STATES DISTRICT COURT ene lis SOUTHERN DISTRICT OF NEW YORK | : eoeeeeueees ay AMERICAN CIVIL LIBERTIES UNION ee AMERICAN CIVIC LIBERTIES UNION #UATE FIL FOUNDATION, - Plait, 07 Civ. 6097 (VM) v. ECF CASE DEPARTMENT OF DEFENSE; CENTRAL INTELLIGENCE AGENCY, Defendants STIPULATION AND ORDER WHEREAS, on May 3, 2007, the Department of Defense ("DOD") and the Central Intelligence Agency (“CIA”) each received a Freedom of Information Act (CFOIA") request from the plaintiffs seeking certain records relating to the DoD’s und the CIA's use of National Security Letters; WHEREAS, on June 28, 2007, the phintiff filed @ complaint initiating this fawsuit, which alleged thot the DOD and the CIA had filed to timely process and produce documents in response to plaintiff’ FOUA requests and sought to require DOD and C1A to expedite processing of these requests and to grant a waiver or limitation of Processing fees; WHEREAS, on September 20, 2007, the parties stipulated to a schedule for processing the r quests and an arrangement concerning processing fees, WHEREAS, pursuant to the stipulation, the processing of plaintifis" FOLA, requests was completed and documents were released to plaintiffs by the CLA ant DOD. by Dovenabrer 31, 2007; P&C RONICALLY FILEDWHEREAS, in consideration of plaintiffs’ agreement to consensually dismiss this action, on March 21, 2008, the DOD released to plaintiffs portions of documents it had previously withheld From disclosure (hereinafter “previously withheld document nd WHEREAS the parties wish to resolve their disputes concerning the FOLA requests without further Titigation; NOW, THEREFOR, [T IS HEREBY STIPULATED AND AGREED, by and among the parties, a fllaws: 1, The panies agree (0 sotle and compromise this getion an the tents get forth below. 2, This action is hereby dismissed with prejudice. 3. The relesse of the records already provided, as well as the previously ‘withheld documents, shall be in full setlement of plants” claims inthis lawscit 4. This Stipulation and Order shal have-no effect or bearing an any other OLA request made by the plaintifs or any other FOLA litigation filed by plaintiff 5. The patties understand and agree thet this Stipulation and Order contains the entire agreement between them, and that no statment, representations, promises, agsoaments, 0° negotiations, oral or otherwise, between the partis or their counse that we pot ingluded herein shall be of any foros or elec, Ae. Dated: New York, New York By: A Z™\ GOODMAN (MG-7844) JAMEL JAFFER (33-4653) ‘American Civil Liberties Union Foundation 125 Broad Street, 18th Floor Now York, New York 10004 Tel: (212) 549-2500 Fax: (212) 549-2629Dated: New York, New York March 242008 SO ORDERED. Die: New Yor, Marche By THEHONORABLE VICTOR A MARRERO | United States Attomey for the Southern Distict of New ork ‘Attorney for Befenday TURNER it United States Attomey 86 Chambers Street ‘New York, New York 10007 ‘Tels 12) 637-2701 Fax: (212) 637-2686 UNITED STATES DISTRICT JUDGE i