Conservation Congress v. United States Forest Service et al

Filing 39

STIPULATION and ORDER signed by Judge Lawrence K. Karlton on 3/15/12: Plaintiff shall file a Supplemental Complaint by March 22, 2012 if no objections from defendants. (Kaminski, H)

1
2
3
4
5
6
7
8

IGNACIA S. MORENO, Assistant Attorney General
SETH M. BARSKY, Chief
S. JAY GOVINDAN, Assistant Chief
ROBERT P. WILLIAMS, Trial Attorney
(DC Bar No. 474730)
MARY HOLLINGSWORTH, Trial Attorney
(AZ Bar No. 027080)
U.S. Department of Justice
Environment & Natural Resources Division
Wildlife & Marine Resources Section
Ben Franklin Station, P.O. Box 7369
Washington, D.C. 20044-7369
[phone] (tel)
[phone] (fax)

9
10

Attorneys for Federal Defendants

11

UNITED STATES DISTRICT COURT FOR THE

12

EASTERN DISTRICT OF CALIFORNIA

13
Sacramento Division

14
15
16
17

CONSERVATION CONGRESS,

CASE NO. 2:11-cv-02605-LKK -EFB

Plaintiff,

18

v.

19

STIPULATED SCHEDULING ORDER FOR
PRELIMINARY INJUNCTION BRIEFING

UNITED STATES FOREST SERVICE, and
UNITED STATES FISH AND WILDLIFE
SERVICE,

20
21

Defendants.

22
23

As directed by the Court during the March 12, 2012 status conference, the parties

24

respectfully submit this stipulated proposed scheduling order setting forth a proposed briefing

25

schedule for Plaintiff’s motion for a preliminary injunction. Federal Defendants and Defendant

26

Intervenor (collectively, “Defendants”), currently anticipate that Project activities will

27
28

1
2

commence on June 1, 2012 in certain high priority units that must be completed no later than
September 30, 2012. Therefore, the parties propose the following briefing schedule:

3
March 19:

Defendants shall advise Plaintiff whether or not they will oppose filing of
the supplemental complaint

March 22:

If Defendants do not oppose the filing of the supplemental complaint,
Plaintiff shall file its supplemental complaint

April 5:

Defendants shall file any responses to the supplemental complaint

April 9:

Plaintiff shall file its motion for preliminary injunction

April 30:

Defendants shall file their oppositions to Plaintiff’s motion for preliminary
injunction

May 7:

5

Plaintiff shall provide Defendants with a draft supplemental complaint

March 21:

4

Plaintiff shall file its reply brief.

6
7
8
9
10
11
12
13
14

Hearing on Plaintiff’s motion for preliminary injunction is set for May 21, 2012 at 10:00
a.m.

15

In the event that Defendants oppose the filing of Plaintiff’s supplemental complaint, the

16

parties shall meet and confer and submit a proposed amended briefing schedule for the Court’s

17

consideration.

18

Dated this 14th day of March, 2012.

19
20

Respectfully Submitted,

21

IGNACIA S. MORENO,
Assistant Attorney General
SETH M. BARSKY, Chief
KRISTEN L. GUSTAFSON,
Assistant Chief

22
23
24

/s/ Robert P. Williams
ROBERT P. WILLIAMS
Trial Attorney
MARY HOLLINGSWORTH

25
26
27
28

CONSERV. CONG. ET AL. V. USFS ET AL. (PROPOSED STIPULATED
SCHEDULING ORDER)

2

11CV02605

1

Trial Attorney
U.S. Department of Justice
Environment & Natural Resources Division
Wildlife & Marine Resources Section
Ben Franklin Station
P.O. Box 7369
Washington, DC 20044-7369
Phone: [phone]
Fax: [phone]
Email: [e-mail]

2
3
4
5
6
7

Attorneys for Federal Defendants

8
9

12

/s/ James J. Tutchton
James J. Tutchton (CA Bar No. 150908)
Tutchton Law Office, LLC
6439 E. Maplewood Ave.
Centennial, CO 80111
Telephone: [phone]
Email: [e-mail]

13

Attorney for Plaintiff

10
11

14
/s/ Julie A. Weis
Julie A. Weis
Pro Hac Vice
email: [e-mail]

15
16

HAGLUND KELLEY JONES & WILDER LLP

17

200 SW Market Street, Suite 1777
Portland, Oregon 97201
Phone: [phone]
Facsimile: [phone]

18
19

Attorneys for Defendant-Intervenor
20
21
22
23

PURSUANT TO STIPULATION, IT IS SO ORDERED
Dated: March 15, 2012

24
25
26
27
28

CONSERV. CONG. ET AL. V. USFS ET AL. (PROPOSED STIPULATED
SCHEDULING ORDER)

3

11CV02605