Natural Resources Defense Council et al v. Norton et al

Filing 964

STIPULATION and ORDER to Extend Filing Deadlines re 963 signed by Magistrate Judge Gary S. Austin on 4/29/2015. (Martinez, A)

COUNSEL IDENTIFICATION ON FINAL PAGE

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

NATURAL RESOURCES DEFENSE
COUNCIL, et al.,
Plaintiffs,

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

v.
SALLY JEWELL, U.S. Department of the
Interior, et al.,

(ECF No. 963)

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

STIPULATION; ORDER
CASE NO. 1:05-CV-01207 LJO-GSA

RECITALS
WHEREAS, on March 23, 2015, the Court issued a Limited Scheduling Order providing a
briefing schedule for motions by Federal Defendants, Defendant-Intervenors and Joined Party
Defendants San Luis & Delta-Mendota Water Authority, et al. (“DMC Contractors”) and GlennColusa Irrigation District, et al. (“SRS Contractors”), to stay and motions to bifurcate this matter,
Doc. 953;
WHEREAS, under the Limited Scheduling Order, the deadline to file those motions was
April 10, 2015; the deadline to file oppositions to the pending motions is April 29, 2015; and the
deadline to file reply briefs is May 8, 2015;
WHEREAS, Federal Defendants, Defendant-Intervenors and Joined Party Defendants
filed motions to stay and to bifurcate on April 10, 2015;
WHEREAS, counsel for Federal Defendants is also attorney of record for the United
States in another matter where a motion for a temporary restraining order and/or preliminary
injunction is expected imminently;
WHEREAS, that expected emergency motion threatens to make Federal Defendants'
counsel’s ability to comply with the Court's schedule in this action unmanageable;
WHEREAS, the parties, by and through their respective counsel of record, as identified
below, have conferred and agree that it is prudent and appropriate to modestly extend the
deadlines under the Court’s Limited Scheduling Order to accommodate Federal Defendants’
counsel’s scheduling conflict, so long as the same length of time is maintained between the
opposition and reply deadlines, and no further extensions on this basis will be sought; and
WHEREAS, the parties agree that the deadline to file oppositions to the pending motions
should be extended to May 5, 2015, and the deadline to file reply briefs should be extended to
May 14, 2015.
STIPULATION
NOW THEREFORE, the parties hereby stipulate as follows regarding the deadline to file
oppositions and reply briefs to the pending motions to stay and bifurcate:
-1-

STIPULATION; ORDER
CASE NO. 1:05-CV-01207 LJO-GSA

The April 29, 2015, deadline to file oppositions shall be extended to May 5, 2015.
The May 8, 2015, deadline to file reply briefs shall be extended to May 14, 2015.
DATED: April 28, 2015

ALTSHULER BERZON LLP
By:

/s/ Hamilton Candee__
Hamilton Candee

HAMILTON CANDEE (SBN 111376)
BARBARA JANE CHISHOLM (SBN 224656)
TONY LOPRESTI (SBN 289269)
ALTSHULER BERZON LLP
177 Post St., Suite 300
San Francisco, CA 94108
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff NRDC
KATHERINE POOLE (SBN 195010)
DOUGLAS ANDREW OBEGI (SBN 246127)
NATURAL RESOURCES DEFENSE COUNCIL
111 Sutter Street, 20th Floor
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff NRDC
TRENT W. ORR (SBN 77656)
TAMARA ZAKIM (SBN 288912)
EARTHJUSTICE
50 California St. Suite 500
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorney for Plaintiffs NRDC, California Trout,
San Francisco Baykeeper, Friends of the River,
and The Bay Institute
DATED: April 28, 2015

U.S. DEPARTMENT OF JUSTICE
ENVIRONMENT & NATURAL RESOURCES
DIVISION
By: /s/ Bradley H. Oliphant (as authorized on
4/28/15)
Bradley H. Oliphant
BRADLEY H. OLIPHANT (SBN 216468)
U.S. DEPARTMENT OF JUSTICE
ENVIRONMENT & NATURAL RESOURCES
DIVISION
999 18th Street
South Terrace, Suite 370
Denver, CO 80202
STIPULATION; ORDER
-2CASE NO. 1:05-CV-01207 LJO-GSA

Telephone: [phone]
Facsimile: [phone]
Attorneys for Respondents Sally Jewell, in her
official capacity as Secretary of the Interior, et al.
DATED: April 28, 2015

SOMACH SIMMONS & DUNN, PC
By: /s/ Andrew M. Hitchings (as authorized on
4/28/15)
Andrew M. Hitchings
STUART L. SOMACH (SBN 90959)
ANDREW M. HITCHINGS (SBN 154554)
SOMACH SIMMONS & DUNN, PC
500 Capitol Mall, Suite 1000
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]
Attorneys for Petitioners Glenn-Colusa Irrigation
District, et al.

DATED: April 28, 2015

KRONICK, MOSKOVITZ, TIEDEMANN &
GIRARD PC
By: _/s/ Daniel J. O’Hanlon_(as authorized on
4/28/15)
Daniel J. O’Hanlon
DANIEL J. O’HANLON (SBN 122380)
HANSPETER WALTER (SBN 244847)
REBECCA ROSE AKROYD (SBN 267305)
KRONICK, MOSKOVITZ, TIEDEMANN &
GIRARD, PC
400 Capitol Mall, 27th Floor
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]
Attorneys for Respondents San Luis & DeltaMendota Water Authority, et al.

DATED: April 28, 2015

DOWNEY BRAND LLP
By: /s/ Steven P. Saxton_(as authorized on
4/28/15)
Steven P. Saxton
STEVEN P. SAXTON (SBN 116943)
DOWNEY BRAND LLP
621 Capitol Mall, 18th Floor
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]
Attorneys for Reclamation District 108, et al.
-3-

STIPULATION; ORDER
CASE NO. 1:05-CV-01207 LJO-GSA

ORDER
Based on the above stipulation between the parties, the Limited Scheduling Order (ECF
No. 953) is modified as follows:
The April 29, 2015, deadline to file oppositions shall be extended to May 5, 2015.
The May 8, 2015, deadline to file reply briefs shall be extended to May 14, 2015.
IT IS SO ORDERED.
Dated:

April 29, 2015

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

STIPULATION; ORDER
CASE NO. 1:05-CV-01207 LJO-GSA