Safari Club International v. Harris et al

Filing 41

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr on 5/29/15: The pretrial scheduling conference is rescheduled for 12/7/2015 at 09:00 AM in Courtroom 10 (GEB) before Judge Garland E. Burrell Jr.. A joint status report shall be filed fourteen days prior to the hearing. (Kaminski, H)

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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
June 22, 2015) and joint status report (currently due June 8, 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 by Order dated April 29, 2015 this Court granted Defendants’ Motion to

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Dismiss Safari Club’s Complaint and granted Safari Club fourteen (14) days to file a First

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Amended Complaint (ECF No. 37);
WHEREAS, on May 13, 2015, Safari Club filed its First Amended Complaint for

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Declaratory and Injunctive Relief (ECF No. 38);
WHEREAS by stipulation of the Parties, Defendants’ last day to answer or otherwise

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respond to Safari Club’s First Amended Complaint is June 17, 2015 (ECF No. 39);

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WHEREAS Defendants anticipate filing a motion to dismiss noticed for hearing on
September 14, 2015, or the earliest date thereafter that is convenient for the Court;

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WHEREAS by stipulation of the Parties and Order of this Court, there currently is a
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status conference set for June 22, 2015, and a joint status report due on June 8, 2015 (ECF No.
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34);
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WHEREAS, due to Defendants’ anticipated motion to dismiss Safari Club’s First

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Amended Complaint, the Parties believe that the preparation of a joint status report by June 8,
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STIPULATION RE CHANGING SCHEDULING CONFERENCE AND JOINT STATUS REPORT DATES (2:14-CV-01856-GEB-

AC)

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2015, and holding of a pretrial scheduling conference on June 22, 2015, are premature and, in the

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interests of efficiency and conservation of judicial and party resources, should be postponed until

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after the Court has resolved the motion to dismiss.

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THEREFORE, in consideration of the foregoing, the Parties respectfully request approval
of this stipulation to grant the following relief:

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The preparation of the joint status report be rescheduled to November 16, 2015, and the
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June 22, 2015 pretrial scheduling conference be rescheduled to November 30, 2015, or the
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earliest dates thereafter that are convenient for the Court.
Dated this 28th day of May, 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 is rescheduled for December 7, 2015, at 9:00

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a.m. A joint status report shall be filed fourteen days prior to the hearing.
Dated: May 29, 2015

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

AC)