Natural Resources Defense Council et al v. Norton et al

Filing 1092

STIPULATION and ORDER to Extend Deadlines, signed by Chief Judge Lawrence J. O'Neill on 6/7/2017. (Motions deadline extended by fourteen days, to and including 6/21/2017.)(Gaumnitz, R)

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COUNSEL IDENTIFICATION ON FINAL PAGE

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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NATURAL RESOURCES DEFENSE
COUNCIL, et al.,

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Plaintiffs,
v.
RYAN K. ZINKE, in his official capacity
as Secretary of the Interior, et al.,
Defendants.

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SAN LUIS & DELTA MENDOTA
WATER AUTHORITY, et al.,
Defendants-Intervenors.
ANDERSON-COTTONWOOD
IRRIGATION DISTRICT, et al.,
Joined Parties.

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STIPULATION AND ORDER TO EXTEND DEADLINES
CASE NO. 1:05-CV-01207 LJO-EPG

Case No. 1:05-cv-01207 LJO-EPG
STIPULATION AND ORDER TO EXTEND
DEADLINES

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WHEREAS, on May 18, 2017, the parties filed the first joint stipulated request to extend

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the deadlines to file all motions regarding completeness of the administrative record, any motions

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or stipulations to limit review of the Sixth Claim as against Federal Defendants to the

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administrative record, and any notice to the Court and parties of intent to seek discovery on the

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Sixth Claim as against Federal Defendants from May 24 to June 7, 2017 (ECF No. 1088), which

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was granted by this Court on the same day (ECF No. 1089);

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WHEREAS, Plaintiffs and Federal Defendants have reached a tentative agreement that will

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avoid motion practice concerning discovery against the Federal Defendants with respect to

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Plaintiffs’ Sixth Claim;

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WHEREAS, in order to promote the efficient resolution of Plaintiffs’ Sixth Claim and

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obviate the need for any discovery as against the Federal Defendants, Federal Defendants are now

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seeking to reach a similar agreement with the SRS Contractors;

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WHEREAS, Plaintiffs and Federal Defendants are diligently working toward resolving

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questions about the scope of the administrative record in an effort to obviate the need for motion

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practice;

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STIPULATION
NOW THEREFORE, counsel for Plaintiffs and Defendants hereby stipulate to and jointly

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request an order extending the deadlines to file all motions regarding completeness of the

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administrative record, any motions or stipulations to limit review of the Sixth Claim as against

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Federal Defendants to the administrative record, and any notice to the Court and parties of intent to

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seek discovery on the Sixth Claim as against Federal Defendants by fourteen days, to and including

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June 21, 2017.

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DATED: June 7, 2017

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/s/_Nicole M. Smith_______
Nicole M. Smith
U.S. DEPARTMENT OF JUSTICE
ENVIRONMENT & NATURAL RESOURCES
DIVISION
601 D Street, NW Room 3712
Washington, D.C. 20044-7611

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STIPULATION AND ORDER TO EXTEND DEADLINES
CASE NO. 1:05-CV-01207 LJO-EPG

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Telephone: [phone]
Facsimile: [phone]
Bradley H. Oliphant, Trial Attorney
U.S. DEPARTMENT OF JUSTICE
ENVIRONMENT & NATURAL RESOURCES
DIVISION
999 18th St., South Terrace, Ste. 370
Denver, CO 80202
Tel: [phone]
Facsimile: [phone]

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Attorneys for Respondents Ryan K. Zinke, in his
official capacity as Secretary of the Interior, et al.

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DATED: June 7, 2017
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/s/ Katherine S. Poole (as authorized on June 7,
2017). Katherine S. Poole

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KATHERINE POOLE (SBN 195010)
DOUGLAS ANDREW OBEGI (SBN 246127)
NATURAL RESOURCES DEFENSE COUNCIL
111 Sutter Street, 21st Floor
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff NRDC

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HAMILTON CANDEE (SBN 111376)
BARBARA JANE CHISHOLM (SBN 224656)
TONY LOPRESTI (SBN 289269)
CORINNE JOHNSON (SB 287385)
ALTSHULER BERZON LLP
177 Post St., Suite 300
San Francisco, CA 94108
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff NRDC

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DATED: June 7, 2017
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/s/Meredith Nikkel (as authorized on June 7, 2017)
Meredith Nikkel
DOWNEY BRAND LLP
621 Capitol Mall, 18th Floor
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Intervenors and Joined Party
Defendants Reclamation District No. 108, Sutter
Mutual Water Company, Natomas Central Mutual
Water Company, River Garden Farms Company,
Pleasant Grove-Verona Mutual Water Company,

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STIPULATION AND ORDER TO EXTEND DEADLINES
CASE NO. 1:05-CV-01207 LJO-EPG

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Pelger Mutual Water Company, Meridian Farms
Water Company, Henry D. Richter, et al., Howald
Farms, Inc., Oji Brothers Farm, Inc., Oji Family
Partnership, Carter Mutual Water Company,
Windswept Land And Livestock Company, Maxwell
Irrigation District, and Tisdale Irrigation and
Drainage Company

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DATED: June 7, 2017

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/s/ Andrew Hitchings (as authorized on June 7, 2017)
Andrew Hitchings
SOMACH SIMMONS & DUNN
A Professional Corporation
500 Capitol Mall, Suite 1000
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Intervenors and Joined Party
Defendants Glenn-Colusa Irrigation District,
Princeton-Codora-Glenn Irrigation District,
Provident Irrigation District, Anderson-Cottonwood
Irrigation District, City Of Redding, M & T Chico
Ranch (Pacific Realty Associates), Reclamation
District No. 1004, Conaway Preservation Group,
LLC, and David and Alice te Velde Family Trust

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DATED: June 7, 2017

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/s/ Daniel J. O’Hanlon (as authorized on June 7
2017)
Daniel J. O’Hanlon
KRONICK, MOSKOVITZ, TIEDEMANN &
GIRARD
A Professional Corporation
400 Capitol Mall, 27th Floor
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant-Intervenors and Joined
Party Defendants, San Luis & Delta-Mendota Water
Authority, Westlands Water District, Coelho Family
Trust, Eagle Field Water District, Fresno Slough
Water District, Mercy Springs Water District, Oro
Loma Water District, and Tranquillity Irrigation
District

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STIPULATION AND ORDER TO EXTEND DEADLINES
CASE NO. 1:05-CV-01207 LJO-EPG

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ORDER
Pursuant to the Parties’ Stipulation, the Court hereby ORDERS that the deadlines to file all

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motions regarding completeness of the administrative record, any motions or stipulations to limit

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review of the Sixth Claim as against Federal Defendants to the administrative record, and any

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notice to the Court and parties of intent to seek discovery on the Sixth Claim as against Federal

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Defendants shall be extended by fourteen days, to and including June 21, 2017.

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IT IS SO ORDERED.
Dated:

/s/ Lawrence J. O’Neill _____

June 7, 2017

UNITED STATES CHIEF DISTRICT JUDGE

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STIPULATION AND ORDER TO EXTEND DEADLINES
CASE NO. 1:05-CV-01207 LJO-EPG

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