USA v. El Dorado County, et al

Filing 449

STIPULATION AND ORDER signed by Chief Judge Morrison C. England, Jr. on 1/5/2015 ORDERING the United States to submit any response brief pursuant to 445 Order by 2/2/2015; ORDERING El Dorado County to submit any reply brief pursuant to 445 Order by 2/17/2015. (Michel, G)

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SAM HIRSCH
Acting Assistant Attorney General
United States Department of Justice
Environment & Natural Resources Division

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Karl J. Fingerhood, Senior Counsel
Andrew J. Doyle, Attorney
P.O. Box 7611
Washington, DC 20044-7611
Telephone: [phone] & [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for United States of America

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THOMAS M. BRUEN (SBN: 63324)
LAW OFFICES OF THOMAS M. BRUEN
A Professional Corporation
1990 N. California Boulevard, Suite 620
Walnut Creek, CA 94596
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for El Dorado County, California

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UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA

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UNITED STATES OF AMERICA,

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Plaintiff,

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No. 2:01-cv-1520-MCE-DAD

v.
EL DORADO COUNTY, CALIFORNIA,

STIPULATION FOR EXTENSION OF
TIME and ORDER

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et al.,
Defendants.

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AND RELATED ACTIONS.

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WHEREAS, on July 8, 2011 (ECF No. 416) the Court entered an Order granting

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Stipulation

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the County’s Motion to Modify the Consent Decree in this matter.

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WHEREAS, by Order entered October 29, 2014 (ECF No. 445) the Court ordered
further briefing on the issues remaining in this dispute.

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WHEREAS, on December 3, 2014, the parties had an in-person mediation, to

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attempt to resolve the remaining issues in dispute before the District Court, as well as
some additional issues.

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WHEREAS, counsel believe that substantial progress was made at the mediation.

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WHEREAS, the parties believe that their time would be best focused on drafting

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an appropriate settlement instrument for review by their clients.

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IT IS HEREBY STIPULATED AND AGREED that the United States shall have

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until, Monday, February 2, 2015 to submit any response brief pursuant to the Court’s
Order dated October 29, 2014 (ECF No. 445). Any reply on behalf of the County must

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be filed no later than February 17, 2015.

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DATED: Dec. 22, 2014

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Respectfully submitted,

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FOR THE UNITED STATES OF AMERICA

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SAMUEL HIRSCH
Acting Assistant Attorney General
Environment & Natural Resources Division
U.S. Department of Justice

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Stipulation

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__/s/ Karl J. Fingerhood___________
KARL J. FINGERHOOD
Senior Counsel
Environmental Enforcement Section
Environment & Natural Resources Division
U.S. Department of Justice

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ANDREW DOYLE
Trial Attorney
Environmental Defense Section
Environment & Natural Resources Division
U.S. Department of Justice

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BENJAMIN B. WAGNER
United States Attorney

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FOR DEFENDANT EL DORADO COUNTY, CALIFORNIA:

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LAW OFFICES OF THOMAS M. BRUEN
A Professional Corporation

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Dated: December 22, 2014

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__/s/ Thomas M. Bruen (with permission by KJF)____
THOMAS M. BRUEN (SBN: 63324)
1990 N. California Boulevard, Suite 620
Walnut Creek, CA 94596
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Stipulation

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Upon consideration of the Parties’ Stipulation for Extension of Time, it is hereby
ORDERED that the stipulation is GRANTED. The United States shall have until,
Monday, February 2, 2015 to submit any response brief pursuant to the Court’s Order
dated October 29, 2014 (ECF No. 445). Any reply on behalf of the County, pursuant to
the Court’s Order dated October 29, 2014 (ECF No. 445), must be filed no later than
February 17, 2015.
IT IS SO ORDERED.

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Dated: January 5, 2015

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Stipulation

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