Brooktrails Township Community Services District v. United States Department of Agriculture, Rural Development et al

Filing 10

STIPULATION AND ORDER re 8 STIPULATION WITH PROPOSED ORDER extending time to respond to complaint and continuing case management conference filed by United States Department of Agriculture, Rural Development Case Management Statement due by 2/19/2013. Initial Case Management Conference set for 2/26/2013 02:00 PM.. Signed by Magistrate Judge Nandor J. Vadas on December 19, 2012. (njvlc2, COURT STAFF) (Filed on 12/19/2012)

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MELINDA HAAG (CSBN 132612)
United States Attorney
ALEX G. TSE (CSBN 152348)
Chief, Civil Division
CLAIRE T. CORMIER (CSBN 154364)
Assistant United States Attorney
150 Almaden Blvd., Suite 900
San Jose, California 95113
Telephone: [phone]
FAX: [phone]
[e-mail]
Specially appearing for
Federal Defendants

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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EUREKA DIVISION

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BROOKTRAILS TOWNSHIP
COMMUNITY SERVICES DISTRICT, a
public agency,

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Plaintiff,

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v.

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UNITED STATES DEPARTMENT OF
AGRICULTURE, RURAL
DEVELOPMENT; JOSEPH SHUNK,
Defendants.

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No. C12-5576 NJV
STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME TO
RESPOND TO COMPLAINT AND
CONTINUING INITIAL CASE
MANAGEMENT CONFERENCE

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The parties previously stipulated that the defendants would have an extension of time

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December 31, 2012 to answer, move, or otherwise respond to the Complaint for Injunctive Relief

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(“Complaint”) in this action if certain partial production of documents was done. That

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production was done, and defendant USDA has committed to a further rolling production with

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the plan of completing the response and production relating to plaintiff’s Freedom of Information

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Act request by January 18, 2013. The parties are hopeful that this rolling production may lead to

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the dismissal of this action.

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In order to allow for the completion of the production and plaintiff’s review of the

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documents and any claimed exemptions, the parties wish to further extend the deadline for

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defendants’ response to the Complaint, as well as the initial case management conference,

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currently scheduled for January 29, 2013.

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Accordingly, pursuant to Civil Local Rule 6-1(a), the parties to this action hereby

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stipulate and request that the defendants shall have an extension of time to January 31, 2013 to

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answer, move, or otherwise respond to the Complaint.

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The parties further stipulate and request that the initial case management conference,

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currently scheduled to take place on January 29, 2013, be continued to February 26, 2013, and

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that the related case management dates be continued accordingly.

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IT IS SO STIPULATED.
Respectfully submitted,

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DATED: December 17, 2012

NEARY and O’BRIEN

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/s/ Christopher J. Neary

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CHRISTOPHER J. NEARY
Attorney for Plaintiffs

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DATED: December 18, 2012

MELINDA HAAG
United States Attorney

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/s/ Claire T. Cormier

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CLAIRE T. CORMIER1
Assistant United States Attorney

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[PROPOSED] ORDER
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Pursuant to the stipulation of the parties and good cause appearing, the deadline for
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defendants to answer, move, or otherwise respond to the Complaint in this action is extended to
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January 31, 2013. The initial case management conference is continued to February 26, 2013,
DISTRI
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_______________________________________
das
or J. Va
NANDOR JudgVADAS
J. e Nand
United States Magistrate Judge
NO

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DATE: December ___, 2012

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D
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UNIT
ED

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OO
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and other case management deadlines are extended accordingly.
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I, Claire T. Cormier, hereby attest that Mr. Neary authorized me to electronically sign
this document on his behalf.
STIPULATION AND [PROPOSED] ORDER RE ANSWER AND CMC CONTINUANCE
Case No. C12-5576 NJV

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