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DEEPAK GUPTA

PUBLIC CITIZEN LITIGATION GROUP

1600 20th Street, NW

Washington, DC 20009

Tel.: (202) 588-1000

Fax: (202) 588-7795

Email: dgupta@citizen.org

MONIQUE OLIVIER

The Sturdevant Law Firm 

A Professional Corporation 

354 Pine Street 

Fourth Floor 

San Francisco, CA 94104 

Tel: (415) 477-2410 

Fax: (415) 477-2420 

Email: molivier@sturdevantlaw.com 

Attorneys for Plaintiffs

TONY WEST

Assistant Attorney General

SANDRA M. SCHRAIBMAN

Assistant Branch Director

RAPHAEL O. GOMEZ

Senior Trial Counsel

PETER D. LEARY

Trial Attorney

UNITED STATES DEPARTMENT OF JUSTICE

Civil Division, Federal Programs Branch

20 Massachusetts Ave., NW, Room 7322

Washington, DC 20044

(202) 514-3313

(202) 616-8470 (fax)

Email: peter.leary@usdoj.gov

Attorneys for Defendant

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

____________________________________

)

PUBLIC CITIZEN, INC., et al. )

Plaintiffs, )

)

v. )

)

ERIC H. HOLDER, JR., )

Defendant. )

____________________________________)

No. CV 08-0833 (MHP)

PLAINTIFFS’ STIPULATION OF

DISMISSAL WITH PREJUDICE

Case 3:08-cv-00833-MHP Document 71 Filed 07/15/10 Page 1 of 2
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28 Public Citizen v. Holder, No. CV 08-0833 (MHP)

Plaintiffs’ Stipulation of Dismissal With Prejudice

- 1 -

In the above-captioned action, Plaintiffs brought suit against the Attorney General alleging

that the Department of Justice (DOJ) had violated the Administrative Procedure Act by failing to:

(1) establish a commencement date for the monthly reporting to the National Motor Vehicle Title

Information System (NMVTIS) of vehicle-history information by insurance carriers and junk and

salvage yard operators; (2) establish by regulation procedures to report that information; and (3)

provide NMVTIS access to prospective car buyers. 

On September 30, 2008, the Court granted Plaintiffs’ Motion for Summary Judgment and

ordered DOJ to: (1) provide instant and reliable consumer access to all reasonably necessary

information present in NMVTIS no later than January 30, 2009; (2) publish a final rule establishing

the procedures for reporting by insurance carriers and junk and salvage yards no later than January

30, 2009; and (3) establish a commencement date for that reporting no later than March 31, 2009.

The parties jointly inform the Court that dismissal of this case is appropriate at this time.

Accordingly, pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii), the parties hereby jointly

stipulate to the dismissal of this action with prejudice. The parties have reached a separate

settlement with respect to costs and fees.

/s/ Peter D. Leary /s/ Deepak Gupta 

PETER D. LEARY DEEPAK GUPTA

Counsel for Defendant Counsel for Plaintiffs

I, Deepak Gupta, as the electronic filer, attest that Peter Leary, whose name appears above,

has concurred in this filing.

/s/ Deepak Gupta 

DEEPAK GUPTA

7/15/2010

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Marilyn H. Patel

Case 3:08-cv-00833-MHP Document 71 Filed 07/15/10 Page 2 of 2