Safari Club International v. Harris et al

Filing 35

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr on 3/30/15. The Final Pretrial Conference is reset for 6/22/2015 at 09:00 AM in Courtroom 10 (GEB) before Judge Garland E. Burrell Jr. Joint status report due no later than 14 days prior to conference. (Manzer, C)

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Linda J. Linton, Esq. (Counsel for Service)
(California Bar No. 177821)
Linton & Associates, P.C.
6900 S. McCarran Blvd., #2040
Reno, NV 89509
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Douglas S. Burdin, Esq.
(D.C. Bar No. 434107)
Anna M. Seidman, Esq.
(D.C. Bar No. 417091)
Safari Club International
501 2nd Street N.E.
Washington, D. C. 20002
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Counsel for Plaintiff
Safari Club International

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IN THE DISTRICT COURT FOR THE
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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SAFARI CLUB INTERNATIONAL

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Plaintiff,
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v.
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KAMALA D. HARRIS, in her official
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capacity as the Attorney General of
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California; CHARLTON H. BONHAM,
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in his official capacity as the Director of
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the California Department of Fish and
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Wildlife,
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Defendants.
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____________________________________)

2:14-cv-01856-GEB-AC

STIPULATION RE
CHANGING SCHEDULING
CONFERENCE AND JOINT
STATUS REPORT DATES

Courtroom: 10, 13th Floor
Judge: Hon. Garland E. Burrell, Jr.
Action Filed: August 6, 2014
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STIPULATION RE CHANGING SCHEDULING CONFERENCE AND JOINT STATUS REPORT DATES (2:14-CV-01856-GEB-

AC)

Plaintiff Safari Club International (“Safari Club”) and Defendants Attorney General

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Kamala D. Harris and Director Charlton H. Bonham (“Defendants,” and collectively with Safari

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Club, the “Parties”), by and through their respective counsel, jointly submit for approval this

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stipulation regarding the rescheduling of the pretrial scheduling conference (currently set for
April 20, 2015) and joint status report (currently due April 4, 2015). In support, the Parties state

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the following:
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WHEREAS, on August 6, 2014, Safari Club filed its Complaint for Declaratory and
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Injunctive Relief.
WHEREAS on October 6, 2014, Defendants filed a Motion to Dismiss Safari Club’s

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Complaint, originally noticed for hearing on November 17, 2014;
WHEREAS by stipulation of the parties and Orders of this Court, the hearing date was

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ultimately rescheduled for April 20, 2015;

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WHEREAS by an Order dated October 17, 2014 (Dkt. 17), the Court scheduled a pretrial

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scheduling conference for April 20, 2015, approximately 10 weeks after the then-current date for

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the hearing on the motion to dismiss (February 2), and ordered the parties to file a joint status

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report 14 days prior to the scheduling conference.

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WHEREAS, due to the pending motion to dismiss Safari Club’s complaint, the Parties

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believe that the preparation of a joint status report by April 6, 2015, and holding of a pretrial
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scheduling conference on April 20, 2015, are premature and, in the interests of efficiency and
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conservation of judicial and party resources, should be postponed until after the Court has
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resolved the motion to dismiss.

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STIPULATION RE CHANGING SCHEDULING CONFERENCE AND JOINT STATUS REPORT DATES (2:14-CV-01856-GEB-

AC)

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WHEREAS, the Court previously set the pretrial scheduling conference for

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approximately 10 weeks after the hearing on the motion to dismiss, the Parties suggest a new

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pretrial scheduling conference be scheduled for June 29, 2015, and the joint status report be due

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14 days prior to this date;

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THEREFORE, in consideration of the foregoing, the Parties respectfully request approval

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of this stipulation to grant the following relief:
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The preparation of the joint status report be rescheduled to June 15, 2015, and the April
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20, 2015 pretrial scheduling conference be rescheduled to June 29, 2015, or the earliest date
thereafter that is convenient for the Court.
Dated this 27th day of March, 2015.

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Respectfully submitted,

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/s/ Douglas S. Burdin
DOUGLAS S. BURDIN
SAFARI CLUB INTERNATIONAL
(D.C. Bar No. 434107)
Pro hac vice granted
Attorney for Plaintiff Safari Club
International

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KAMALA D. HARRIS
Attorney General of California
TAMAR PACHTER
Supervising Deputy Attorney General

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/s/ Alexandra Robert Gordon
ALEXANDRA ROBERT GORDON
Deputy Attorney General
Attorneys for Defendants Attorney General
Harris & Director Bonham

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STIPULATION RE CHANGING SCHEDULING CONFERENCE AND JOINT STATUS REPORT DATES (2:14-CV-01856-GEB-

AC)

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HAVING CONSIDERED THE STIPULATION OF THE PARTIES, AND GOOD CAUSE
APPEARING, IT IS SO ORDERED:

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The pretrial scheduling conference, currently scheduled for April 20, 2015, is rescheduled

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for June 22, 2015 at 9:00 a.m. A joint status report shall be filed fourteen days prior to the

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hearing.

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Dated: March 30, 2015
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STIPULATION RE CHANGING SCHEDULING CONFERENCE AND JOINT STATUS REPORT DATES (2:14-CV-01856-GEB-

AC)