Approved for public release by the DNI 20140909 CR 0653 UNITED STATES FOREIGN INTELLIGENCE SURVEILLANCE COURT A :3 I DC - {s Ogre IN RE DIRECTIVES TO YAHOO INC. PURSUANT TO SECTION 1053 OF THE FOREIGN INTELLIGENCE SURVEILLANCE ACT. 15K Docket Number: 1053(3) 07-01 GOVERNMENTS MOTION FOR AN ORDER OF CIVIL CONTEMPT (U) The United States of America, through the undersigned Department of ]ustice attorneys, hereby re5pecti'ully moves for an order holding Yahoo!, Inc. Civil contempt for failing to comply with the Court?s Order of April 25, 2008, if the Court denies Yahoo?s motion for a stay pending appeal and if Yahoo fails to begin compliance . with the Court?s Order within twenty?four hours of the Court?s denial of Yahoo?s motion for a stay. The Government further respectfully requests that the Court's contempt order direct Yahoo'to pay the Court a coercive fine of a minimum of $250,000 for each additional day that Yahoo fails to comply, wim the fine to double for each successive week that Yahoo fails to con-11:ler with the Court?s April 25, 2008 Order. (81 Classi?ed by: Reason: - Declassify on: Matthew G. Olsen, Deputy Assistant Attorney General, N313, 1.4 8 May 2033 221 Approved for public release by the DNI 20140909 CR 0654 The grounds for the Government?s motion are set forth in the accompanying Combined Memorandum in Opposition to Yahoo?s Motion for Stay Pending Appeal and in Support of the Govermnent?s Motion for an Order of Civil Contempt. A proposed order accompanies this motion. Respectftu submitted, Matthevl/ (3. Olsen Deputy Assistant Attorney General John C. Demers - Deputy Assistant Attorney General Counsel to the Assistant Attorney General Office of Intelligence Counsel for National Security Law Policy Office of Law and Policy National Security Division United States Department of Justice 222