Sierra Club et al v. Jackson et al

Filing 31

ORDER GRANTING 30 STIPULATION TO EXTEND TIME FOR FILING MOTION FOR ATTORNEY'S FEES. Signed by Judge Jeffrey S. White on 6/21/12. (jjoS, COURT STAFF) (Filed on 6/21/2012)

Case3:11-cv-03106-JSW Document30 Filed06/20/12 Page1 of 3

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PAUL R. CORT, State Bar No. 184336
WENDY S. PARK, State Bar No. 237331
Earthjustice
50 California Street, Suite 500
San Francisco, CA 94111
[e-mail]
[e-mail]
Tel: [phone] / Fax: [phone]
Attorneys for Plaintiffs Sierra Club and
Medical Advocates for Healthy Air

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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO/OAKLAND DIVISION

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)
)
)
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Plaintiffs,
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v.
)
)
LISA P. JACKSON, in her official capacity as
)
Administrator of the United States Environmental )
Protection Agency, and JARED BLUMENFELD, in)
his official capacity as Regional Administrator for )
Region IX of the United States Environmental
)
Protection Agency,
)
)
Defendants.
)
SIERRA CLUB and MEDICAL ADVOCATES
FOR HEALTHY AIR,

Case No: C 11-03106-JSW
JOINT STIPULATION TO EXTEND
TIME FOR FILING MOTION FOR
ATTORNEY’S FEES
and
[PROPOSED] ORDER

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WHEREAS,

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1.

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On March 26, 2012, this Court signed and entered a Consent Decree resolving

plaintiffs’ claims in this action (Dkt. 27);
2.

Under the terms of the Consent Decree, plaintiffs’ motion for attorney’s fees and

litigation costs is due on June 25, 2012, see id. ¶ 10;
3.

The parties may stipulate to an extension of the time for filing plaintiffs’ motion for

attorney’s fees and costs, see id. ¶ 4;
4.

Plaintiffs and defendants have reached an agreement settling plaintiffs’ claims for

attorney’s fees and costs but need additional time to carry out the terms of the agreement;
JOINT STIPULATION TO EXTEND TIME – CASE NO. C 11-30106-JSW

Case3:11-cv-03106-JSW Document30 Filed06/20/12 Page2 of 3

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5.

An additional 91-day extension of the June 25, 2012 attorneys’ fees and costs motion

deadline would afford the parties the time needed to do so without resort to further litigation;
THEREFORE, the parties, through their undersigned counsel, stipulate and request this Court

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to order that plaintiffs shall serve and file a motion for attorney’s fees and costs, if necessary, by

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September 24, 2012. Defendants’ counsel has authorized counsel for plaintiffs to sign and file this

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stipulation jointly on the parties’ behalf.

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Respectfully submitted,

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PAUL R. CORT

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/s/ Wendy S. Park
WENDY S. PARK
EARTHJUSTICE
50 California Street, Suite 500
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]

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Counsel for Plaintiffs

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Dated: June 20, 2012

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IGNACIA S. MORENO
Assistant Attorney General
Environment and Natural Resources Division

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Dated: June 20, 2012

/s/ Martin F. McDermott
MARTIN F. McDERMOTT
Trial Attorney
United States Department of Justice
Environment and Natural Resources Division
Environmental Defense Section
601 D Street, N.W.
Washington, D.C. 20004
Phone: [phone]
Email: [e-mail]

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JOINT STIPULATION TO EXTEND TIME – CASE NO. C 11-30106-JSW

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Case3:11-cv-03106-JSW Document30 Filed06/20/12 Page3 of 3

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[PROPOSED] ORDER

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IT IS SO ORDERED. Plaintiffs shall serve and file a motion for attorney’s fees and litigation

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costs, if necessary, by September 24, 2012.

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June 21, 2012
Dated: _________________

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__________________________________
UNITED STATES DISTRICT JUDGE

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JOINT STIPULATION TO EXTEND TIME – CASE NO. C 11-30106-JSW

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