AquAlliance et al v. U.S. Bureau of Reclamation, et al

Filing 88

JOINT STIPULATION TO EXTEND TIME ON SUPPLEMENTAL FILING FOR MOTION/PETITION FOR ATTORNEYS FEES, COSTS, AND EXPENSES; ORDER signed by Chief Judge Lawrence J. O'Neill on July 26, 2018. (Munoz, I)

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Jason R. Flanders (SBN 238007)
AQUA TERRA AERIS LAW GROUP
490 43rd St., Ste. 108
Oakland, CA 94609
Phone: [phone]
Email: [e-mail]
Michael B. Jackson (SBN 53808)
P.O. Box 207
75 Court Street
Quincy, CA 95971
Phone: [phone]
Email: [e-mail]
Attorneys for Petitioners and Plaintiffs AquAlliance and
California Sportfishing Protection Alliance

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Patrick M. Soluri (SBN 210036)
Osha R. Meserve (SBN 204240)
SOLURI MESERVE, A LAW CORPORATION
510 8th Street
Sacramento, CA 95814
Phone: [phone]
Email: [e-mail]; [e-mail]
Attorneys for Petitioners and Plaintiffs Local Agencies of the North Delta,
Central Delta Water Agency, South Delta Water Agency

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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AQUALLIANCE; CALIFORNIA
SPORTFISHING PROTECTION ALLIANCE;
CENTRAL DELTA WATER AGENCY;
SOUTH DELTA WATER AGENCY; LOCAL
AGENCIES OF THE NORTH DELTA,
Petitioners and Plaintiffs,

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v.

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JOINT STIPULATION TO EXTEND TIME ON
SUPPLEMENTAL FILING FOR
MOTION/PETITION FOR ATTORNEYS FEES,
COSTS, AND EXPENSES; [PROPOSED]
ORDER
Hon. Lawrence O’Neill

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1:15-cv-00754-LJO-BAM

THE UNITED STATES BUREAU OF
RECLAMATION; SAN LUIS & DELTAMENDOTA WATER AUTHORITY; U.S. FISH
AND WILDLIFE SERVICE; U.S.
DEPARTMENT OF THE INTERIOR; SALLY
JEWELL, in her official capacity; and DOES 1 –
100,

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Respondents and Defendants.
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Joint Stipulation to Extend Time on Supplemental Filing

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STIPULATION

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PLAINTIFFS, AquAlliance, California Sportfishing Protection Alliance, Central Delta Water

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Agency, South Delta Water Agency and Local Agencies of the North Delta; and DEFENDANTS,

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United States Bureau of Reclamation, United States Fish and Wildlife Service, and San Luis & Delta-

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Mendota Water Authority file this Joint Stipulation and [Proposed] Order to extend time for

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supplemental and response filings regarding Plaintiffs’ preliminary Motion/Petition for Attorneys’ Fees,

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Costs, and Expenses, filed concurrently herewith.

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WHEREAS, on June 29, 2018, the Parties lodged a Proposed Final Judgment with the intent that
all applicable timelines regarding Plaintiffs’ claims for recovery of fees and costs be extended at least

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thirty (30) days to enable sufficient time for the parties to meet and confer and negotiate in good faith in

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an attempt to resolve Plaintiffs’ claims without further litigation;

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WHEREAS, on July 5, 2018, the Court entered Judgment in this matter;

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WHEREAS, the parties have met and conferred and desire additional time to negotiate in good

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faith to attempt to resolve Plaintiffs’ claims without further litigation;

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WHEREAS, Plaintiffs are filing, concurrently with this Stipulation and Proposed Order, a
preliminary Motion/Petition for Attorneys’ Fees, Costs, and Expenses; and,

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WHEREAS, in furtherance of the intent of the Parties to negotiate in good faith to resolve

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Plaintiffs’ claims for fees and costs without further litigation, no party will contest the timeliness of

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Plaintiffs’ Motion/Petition for Attorneys’ Fees, Costs, and Expenses, subject to the deadlines agreed to,

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below:

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NOW, THEREFORE, THE PARTIES STIPULATE AND AGREE:

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Plaintiffs shall have until September 5, 2018 to file a Supplemental Motion/Petition for

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Attorneys’ Fees, Costs, and Expenses, and Supplemental Memorandum in Support thereof not to exceed

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twenty (20) pages in length;

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Defendants’ opposition brief(s) shall be filed no later than October 5, 2018, and shall not exceed
forty (40) pages combined;
Plaintiffs’ may file a single combined reply brief no later than October 25, which shall not
exceed twenty-five (25) pages.
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Joint Stipulation to Extend Time on Supplemental Filing, Order

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Dated: July 20, 2018

AQUA TERRA AERIS LAW GROUP
By: /s/ Jason R. Flanders_
Jason R. Flanders
Attorneys for Petitioners
AquAlliance, California Sportfishing
Protection Alliance

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Dated: July 20, 2018

SOLURI MESERVE, A LAW CORPORATION
By: /s/ Patrick M. Soluri
Patrick M. Soluri
Attorney for Plaintiffs
Local Agencies of the North Delta, Central
Delta Water Agency, South Delta Water Agency

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Dated: July 20, 2018

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By: /s/ Daniel J. O’Hanlon
Daniel J. O’Hanlon
Attorneys for Defendant/Respondent,
San Luis & Delta-Mendota Water Authority

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KRONICK, MOSKOVITZ, TIEDEMANN &
GIRARD
A Professional Corporation

Dated: July 20, 2018

JEFFREY H. WOOD
Acting Assistant Attorney General
By: /s/ Lee Leininger
R. LEE LEININGER
Natural Resources Section
999 18th Street
South Terrace, Suite 370
Denver, CO 80202
Phone: [phone]; Fax: [phone]
[e-mail]

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CLIFFORD E. STEVENS, JR.
U.S. Department of Justice
Environment & Natural Resources Division
Wildlife & Marine Resources Section
Ben Franklin Station, P.O. Box 7611
Washington, D.C. 20044-7611
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Joint Stipulation to Extend Time on Supplemental Filing, Order

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Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Federal Defendants

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Joint Stipulation to Extend Time on Supplemental Filing, Order

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ORDER
Pursuant to Stipulation of the Parties, it is so ORDERED:

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Plaintiffs shall have until September 5, 2018 to file a Supplemental Motion/Petition for

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Attorneys’ Fees, Costs, and Expenses, and a Supplemental Memorandum in Support thereof not to

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exceed twenty (20) pages in length;
Defendants’ opposition brief(s) shall be filed no later than October 5, 2018, and shall not exceed

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forty (40) pages combined1; and
Plaintiffs’ may file a single combined reply brief no later than October 25, which shall not

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exceed twenty-five (25) pages.
Given this Court’s present and anticipated workload, the parties are reminded to make every

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effort to present to the Court only issues that are truly in dispute and to do so in the most efficient

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manner possible.

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IT IS SO ORDERED.

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Dated:
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July 26, 2018

/s/ Lawrence J. O’Neill _____
UNITED STATES CHIEF DISTRICT JUDGE

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No individual Defendant’s brief may exceed the normal page limit (25 pages).

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Joint Stipulation to Extend Time on Supplemental Filing, Order