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| UNITED STATES DISTRICT COURT|
FOR THE DISTRICT OF COLUMBIA
NOTICE OF PROPOSED STIPULATED
SCHEDULING AND CASE-MANAGEMENT ORDER
Plaintiff United States on behalf of Plaintiffs and Defendants respectfully requests the Court, pursuant to Fed. R. Civ. P. 16(b) and LCvR 16.4, to enter the attached Stipulated Scheduling and Case-Management Order and resolve the parties' disputes about the dates in paragraph 11. Plaintiff States do not object. Pursuant to LCvR 7(m), counsel for the parties have conferred and reached agreement on the language, but cannot reach agreement on the highlighted dates just in paragraph 11. As highlighted in the proposed Order, the United States' proposed date appears and then the Defendants' proposed date (i.e., [United States/Defendants]).
Dated this 23rd day of September 2011.