Vietnam Veterans of America, et al. v. Central Intelligence Agency, et al.
Case No. CV-09-0037-CW, U.S.D.C. (N.D. Cal. 2009)

Court-Filed Documents

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• Defendants’ Motion for A Protective Order Staying Further Discovery and for Modification of Case Management Order [8/27/10]
• Declaration of Michael Kilpatrick, Director, Strategic Communications office of The Under Secretary of Defense for Health Affairs [8/27/10]
• Declaration of Patricia Cameresi, Associate Information Review Officer, Directorate of Science & Technology, Central Intelligence Agency [8/27/10]
• Declaration of Caroline Lewis Wolverton [8/27/10]
• [Proposed] Order Granting Defendants’ Motion for a Protective Order Staying Further Discovery and Revising Case Management Schedule [8/27/10]
• Plaintiffs’ Notice of Motion and Motion to Overrule Objections and Compel Production of Documents and Memorandum of Points and Authorities in Support Thereof [8/25/10]
• Declaration of Daniel J. Vecchio in Support of Plaintiffs’ Motion to Overrule Objections and Compel Production of Documents [8/25/10]
  • Exhibit A [8/25/10]
  • Exhibit B [8/25/10]
  • Exhibit C [8/25/10]
  • Exhibit D [8/25/10]
  • Exhibit E [8/25/10]
  • Exhibit F [8/25/10]
  • Exhibit G [8/25/10]
  • Exhibit H [8/25/10]
  • Exhibit I [8/25/10]
  • Exhibit J [8/25/10]
  • Exhibit K [8/25/10]
  • Exhibit L [8/25/10]
• [Proposed] Order Granting Plaintiffs’ Motion to Overrule Objections and Compel Production of Documents [8/25/10]
• Plaintiffs’ Notice of Motion and Motion to Overrule Objections and Compel 30(b)(6) Depositions and Memorandum of Points and Authorities in Support Thereof [8/25/10]
• Declaration of Daniel J. Vecchio in Support of Plaintiffs’ Motion to Overrule Objectons and Compel 30(b)(6) Depositions [8/25/10]
  • Exhibit A [8/25/10]
  • Exhibit B [8/25/10]
  • Exhibit C [8/25/10]
  • Exhibit D [8/25/10]
  • Exhibit E [8/25/10]
  • Exhibit F [8/25/10]
  • Exhibit G [8/25/10]
  • Exhibit H [8/25/10]
  • Exhibit I [8/25/10]
  • Exhibit J [8/25/10]
  • Exhibit K [8/25/10]
  • Exhibit L [8/25/10]
  • Exhibit M [8/25/10]
  • Exhibit N [8/25/10]
• [Proposed] Order Granting Plaintiffs’ Motion to Overrule Objections and Compel 30(b)(6) Depositions [8/25/10]
• Plaintiffs’ Notice of Motion and Motion for Sanctions [8/25/10]
• Declaration of Daniel J. Vecchio in Support of Plaintiffs’ Motion for Sanctions [8/25/10]
  • Exhibit A [8/25/10]
  • Exhibit B [8/25/10]
  • Exhibit C [8/25/10]
  • Exhibit D [8/25/10]
  • Exhibit E [8/25/10]
  • Exhibit F [8/25/10]
  • Exhibit G [8/25/10]
• [Proposed] Order Granting Plaintiffs’ Motion for Sanctions [8/25/10]
• Notice of Motion & Motion for Protective Order and to Overrule Objections [8/19/10]
• Declaration of Daniel J. Vecchio in Support of Plaintiffs’ Motion for Protective Order [8/19/10]
  • Exhibit A [8/19/10]
  • Exhibit B [8/19/10]
  • Exhibit C [8/19/10]
  • Exhibit D [8/19/10]
  • Exhibit E [8/19/10]
  • Exhibit F [8/19/10]
  • Exhibit G [8/19/10]
  • Exhibit H-1 [8/19/10]
  • Exhibit H-2 [8/19/10]
  • Exhibit I [8/19/10]
  • Exhibit J [8/19/10]
  • Exhibit K [8/19/10]
  • Exhibit L [8/19/10]
  • Exhibit M [8/19/10]
• [Proposed] Protective Order Governing Discovery [8/19/10]
• Reply in Support of Plaintiffs’ Motion for Leave to File Third Amended Complaint [7/15/10]
  • Exhibit 1 [7/15/10]
• Defendants’ Opposition to Plaintiffs’ Motion for Leave to Amend Complaint [6/24/10]
  • Exhibit A [6/24/2010]
  • Exhibit B [6/24/2010]
• Plaintiffs’ Notice of Errata [6/11/10]
• Notice of Motion & Motion for Leave to File Third Amended Complaint [6/7/10]
• Memorandum of Points and Authorities in Support of Plaintiffs’ Motion for Leave to File Third Amended Complaint [6/7/10]
  • Exhibit A (Third Amended Complaint) [6/7/10]
    • Exhibit A (to Third Amended Complaint) [6/7/10]
    • Exhibit B (to Third Amended Complaint) [6/7/10]
    • Exhibit C (to Third Amended Complaint) [6/7/10]
• Declaration of Gordon P. Erspamer in Support of Plaintiffs’ Motion for
  Leave to File Third Amended Complaint [6/7/10]
• [Proposed] Order Granting Plaintiffs’ Motion for Leave to File Third
  Amended Complaint [6/7/10]
• Defendants’ Amended Answer to Second Amended Complaint [4/7/10]
• Defendants’ Answer to Second Amended Complaint [3/17/10]
• Order Granting in Part and Denying in Part Defendants’ Motions to Dismiss and Denying Defendants’ Alternative Motion for Summary Judgment [1/19/10]
• Clerk’s Notice Taking Motion Under Submission [1/8/10]
• [Proposed] Order Granting Defendants’ Motion to Dismiss Second Amended Complaint [1/5/10]
• Defendants’ Motion to Dismiss Second Amended Complaint or in the Alternative for Summary Judgment [1/5/10]
  • Attachment 1 [1/5/10]
  • Attachment 2 [1/5/10]
  • Attachment 3 [1/5/10]
  • Exhibit A, Declaration of Kimberly J. Albers [1/5/10]
  • Exhibit B, Declaration of Paul Weiss [1/5/10]
  • Exhibit C, Declaration of Ena Lima [1/5/10]
  • Exhibit D, Declaration of Clyde Bennett [1/5/10]
• Notice of Settlement Conference and Settlement Conference Order [12/31/09]
• Minute Order and Case Management Order [12/23/09]
• Second Amended Complaint for Declaratory and Injunctive Relief Under United States Constitution and Federal Statutes [12/17/09]
  • Exhibit A [12/17/09]
  • Exhibit B [12/17/09]
  • Exhibit C [12/17/09]
• Motion to Dismiss Oral Argument Hearing Transcript [12/3/09]
• Stipulation and Order Continuing Hearing on Defendants’ Motion to Dismiss First Amended Complaint and Initial Case Management Conference [10/29/09]
• Stipulation and [Proposed] Order Continuing Hearing on Defendants’ Motion to Dismiss First Amended Complaint and Initial Case Management Conference [10/28/09]
• Declaration of Adriano Hrvatin In Support of Stipulation and [Proposed] Order Continuing Hearing on Defendants’ Motion to Dismiss First Amended Complaint and Initial Case Management Conference [10/28/09]
• Defendants’ Reply in Support of Their Motion to Dismiss First Amended Complaint [10/23/09]
  • Attachment 1 [10/23/09]
  • Attachment 2 [10/23/09]
  • Attachment 3 [10/23/09]
• Order Granting Defendants’ Motion to Seal [10/7/09]
• Plaintiffs’ Opposition to Defendants’ Motion to Dismiss First Amended Complaint [10/2/09]
• Order Concerning Potentially Sealable Documents [8/31/09]
• Defendants’ Motion to Dismiss First Amended Complaint [8/14/09]
  • Exhibit A, Declaration of Kimberly J. Albers [8/14/09]
  • Exhibit B, Declaration of Paul Weiss [8/14/09]
  • Exhibit C, Declaration of Ena Lima [8/14/09]
  • Exhibit D, Declaration of Clyde Bennett [8/14/09]
• First Amended Complaint for Declaratory and Injunctive Relief Under United States Constitution and Federal Statutes [7/24/09]
  • Exhibit A [7/24/09]
  • Exhibit B [7/24/09]
  • Exhibit C [7/24/09]
• Defendants’ Motion to File Privacy-Act Covered Records Under Seal in the Non-Public Docket [6/30/09]
  • Declaration of Caroline Lewis Wolverton in Support of Defendants’ Motion to File Privacy-Act Protected Records Under Seal in the Non-Public Docket [6/30/09]
• Defendants’ Motion to Dismiss [6/30/09]
  • Attachment 1 - Declaration of Kimberly J. Albers [6/30/09]
  • Attachment 2 - Declaration of Paul Weiss [6/30/09]
  • Attachment 3 - Declaration of Ena Lima [6/30/09]
  • Attachment 4 - Declaration of Clyde Bennett [6/30/09]
• Complaint for Declaratory and Injunctive Relief Under United States Constitution [1/7/09]
  • Exhibit A [1/7/09]
  • Exhibit B [1/7/09]
  • Exhibit C [1/7/09]