San Luis & Delta-Mendota Water Authority et al v. Jewell et al

Filing 23

STIPULATION and ORDER Extending Schedule for Briefing, signed by Chief Judge Lawrence J. O'Neill on 10/6/17. (Hellings, J)

1 DANIEL J. O’HANLON, State Bar No. 122380
REBECCA R. AKROYD, State Bar No. 267305
2 KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD
A Professional Corporation
3 400 Capitol Mall, 27th Floor
Sacramento, California 95814
4 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Plaintiffs, SAN LUIS & DELTA6 MENDOTA WATER AUTHORITY and
WESTLANDS WATER DISTRICT
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JON D. RUBIN, State Bar No. 196944
8 General Counsel
SAN LUIS & DELTA-MENDOTA WATER AUTHORITY
9 400 Capitol Mall, 28th Floor
Sacramento, CA 95814
10 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Plaintiff, SAN LUIS & DELTA12 MENDOTA WATER AUTHORITY
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Additional Counsel on Next Page
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SAN LUIS & DELTA-MENDOTA WATER
18 AUTHORITY and WESTLANDS WATER
DISTRICT,
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Plaintiffs,
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v.
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SALLY JEWELL, as Secretary of the U.S.
22 Department of the Interior; U.S.
DEPARTMENT OF THE INTERIOR; U.S.
23 BUREAU OF RECLAMATION; ESTEVAN
LOPEZ, as Commissioner, Bureau of
24 Reclamation, U.S. Department of the Interior
and DAVID MURILLO, as Regional Director,
25 Mid-Pacific Region, Bureau of Reclamation,
U.S. Department of the Interior,
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Defendants.
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Case No. 1:16-cv-00983-LJO-EPG
STIPULATION AND ORDER
EXTENDING SCHEDULE FOR
BRIEFING

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1606622.1 10355-069

STIPULATION AND ORDER EXTENDING SCHEDULE FOR BRIEFING

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ADDITIONAL COUNSEL

2 PHILIP A. WILLIAMS, State Bar No. 296683
General Counsel
3 WESTLANDS WATER DISTRICT
400 Capitol Mall, 28th Floor
4 Sacramento, CA 95814
Telephone: [phone]
5 Facsimile: [phone]
6 Attorneys for Plaintiff, WESTLANDS WATER DISTRICT
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1606622.1 10355-069

STIPULATION AND [PROPOSED] ORDER EXTENDING SCHEDULE FOR BRIEFING

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RECITALS
WHEREAS, the June 16, 2017 Stipulation and Order Extending Schedule for Briefing

3 (Doc. 18) provided the following schedule for the filing of cross-motions for summary judgment:
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September 28, 2017

Plaintiffs shall file their motion for summary judgment.

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November 28, 2017

Defendants shall file their combined cross-motion for summary
judgment and opposition to Plaintiffs’ motion for summary
judgment.

December 28, 2017

Plaintiffs shall file their combined opposition to Defendants’
cross-motion for summary judgment and reply in support of
Plaintiff’s motion for summary judgment.

January 28, 2018

Defendants shall file their reply in support of their cross-motion
for summary judgment.

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WHEREAS, the parties are continuing to pursue discussions that may avoid the necessity

12 of filing cross-motions for summary judgment in this case;
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WHEREAS, the parties agree that in light of these discussions, a ninety-day extension of

14 the schedule for the filing of cross-motions for summary judgment is appropriate, and agree to
15 request such an extension from the Court;
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AND WHEREAS, the parties agree that the revised schedule should be as follows:

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December 27, 2017

Plaintiffs shall file their motion for summary judgment.

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February 26, 2018

Defendants shall file their combined cross-motion for summary
judgment and opposition to Plaintiffs’ motion for summary
judgment.

March 28, 2018

Plaintiffs shall file their combined opposition to Defendants’
cross-motion for summary judgment and reply in support of
Plaintiff’s motion for summary judgment.

April 28, 2018

Defendants shall file their reply in support of their cross-motion
for summary judgment.

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1606622.1 10355-069

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STIPULATION AND ORDER EXTENDING SCHEDULE FOR BRIEFING

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STIPULATION
NOW THEREFORE, counsel for the parties hereby stipulate to, and jointly request that the

3 Court grant, a ninety-day extension of the schedule for the filing of cross-motions for summary
4 judgment provided in the June 16, 2017 Stipulation and Order Extending Schedule for Briefing
5 making the new schedule for briefing as follows:
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December 27, 2017

Plaintiffs shall file their motion for summary judgment.

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February 26, 2018

Defendants shall file their combined cross-motion for summary
judgment and opposition to Plaintiffs’ motion for summary
judgment.

March 28, 2018

Plaintiffs shall file their combined opposition to Defendants’
cross-motion for summary judgment and reply in support of
Plaintiff’s motion for summary judgment.

April 28, 2018

Defendants shall file their reply in support of their cross-motion
for summary judgment.

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14 DATED: September 19, 2017
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KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD
A Professional Corporation

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By:

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/s/ Daniel J. O’Hanlon
Daniel J. O’Hanlon
Attorneys for Plaintiffs, SAN LUIS & DELTAMENDOTA WATER AUTHORITY and
WESTLANDS WATER DISTRICT

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1606622.1 10355-069

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STIPULATION AND ORDER EXTENDING SCHEDULE FOR BRIEFING

1 DATED: September 19, 2017
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JEFFREY H. WOOD
Acting Assistant Attorney General
U.S. Department of Justice
Environment and Natural Resources Division

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By:

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/s/ Anna K. Stimmel
ANNA K. STIMMEL
Senior Attorney
Natural Resources Section
301 Howard Street, Suite 1050
San Francisco, CA 94105
[phone] (Tel); [phone] (Fax)
[e-mail]
Counsel for Federal Defendants

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1606622.1 10355-069

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STIPULATION AND ORDER EXTENDING SCHEDULE FOR BRIEFING

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ORDER
Pursuant to the parties’ stipulation (Doc. 19) and supplemental declarations (Docs. 21-22),

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3 the Court hereby ORDERS that the schedule for briefing in the June 16, 2017 Stipulation and
4 Order Extending Schedule for Briefing (Doc. 18) be extended by ninety days, and be established
5 as follows:
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Plaintiffs shall submit their motion for summary judgment on or before December 27,

7 2017.
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Defendants shall submit their combined cross-motion for summary judgment and

9 opposition to Plaintiffs’ motion for summary judgment on or before February 26, 2018.
Plaintiffs shall submit their combined opposition to Defendants’ cross-motion for summary

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11 judgment and reply in support of Plaintiff’s motion for summary judgment on or before March 28,
12 2018.
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Defendants shall submit their reply in support of their cross-motion for summary judgment

14 on or before April 28, 2018.
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16 IT IS SO ORDERED.
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Dated:

/s/ Lawrence J. O’Neill _____

October 6, 2017

UNITED STATES CHIEF DISTRICT JUDGE

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1606622.1 10355-069

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STIPULATION AND ORDER EXTENDING SCHEDULE FOR BRIEFING