Basel Action Network et al v. U.S. Environmental Protection Agency et al

Filing 53

STIPULATION AND ORDER re 51 STIPULATION WITH PROPOSED ORDER Request to Appear Telephonically for Initial Case Management Conference filed by U.S. Environmental Protection Agency, Lisa P. Jackson. Signed by Judge Edward M. Chen on 9/24/12. (bpf, COURT STAFF) (Filed on 9/24/2012)

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IGNACIA S. MORENO
Assistant Attorney General
Environment & Natural Resources Division
United States Department of Justice
LESLIE M. HILL (D.C. Bar No. 476008)
[e-mail]
Environmental Defense Section
601 D Street N.W., Suite 8000
Washington D.C. 20004
Telephone [phone]
Facsimile [phone]

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Attorneys for Defendants

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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Case No.: CV-11-06185-EMC

BASEL ACTION NETWORK, et al. ,
Plaintiffs,

JOINT REQUEST TO APPEAR
TELEPHONICALLY FOR INITIAL
CASE MANAGEMENT
CONFERENCE AND [PROPOSED]
ORDER

v.
U.S. Environmental Protection Agency,
et al.,
Defendants.

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Pursuant to Civil L.R. 6-2, Defendant United States Environmental Protection

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Agency (“EPA”) and Lisa P. Jackson, Administrator, U.S. EPA, in her official capacity

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(collectively “Defendants”), and the Basel Action Network (“BAN”), Sierra Club, and

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the Center for Biological Diversity (collectively “Plaintiffs”), hereby stipulate to and

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request an order allowing the parties to appear telephonically for the initial Case

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Management Conference (“CMC”) at 9:00 am on September 28, 2012.

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Lead counsel for EPA is located in Washington, D.C., and, due to current

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government budgetary restrictions, has not received approval to travel to San Francisco
CASE NO. CV-11-06185-EMC
JOINT REQUEST TO APPEAR TELEPHONICALLY FOR INITIAL CASE MANAGEMENT
CONFERENCE AND [PROPOSED] ORDER

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for the CMC. No local Department of Justice attorneys are assigned to this matter and no

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other Department of Justice attorneys have worked on this matter in any capacity. Lead

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counsel for Plaintiffs is located in Seattle, WA and does not object to this request so long

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as both parties appear telephonically.

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Therefore, for the reasons stated above, the parties request that they both be
allowed to appear and participate telephonically at the September 28, 2012 initial CMC.

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Respectfully submitted,

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Date: September 21, 2012

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

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___________/s/_________________
LESLIE M. HILL (D.C. Bar No. 476008)
U.S. Department of Justice
Environment & Natural Resources Division
Environmental Defense Section
601 D Street N.W., Suite 8000
Washington D.C. 20004
[e-mail]
Telephone [phone]
Facsimile [phone]
Attorneys for Defendants

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/s/ (electronic mail authorization 9/18/12)
AMANDA W. GOODIN (WSB #41312)
TODD D. TRUE (WSB #12864)
[Appearing Pro Hac Vice]
Earthjustice
705 Second Avenue, Suite 203
Seattle, WA 98104
[phone] | Phone
[phone] | Fax
[e-mail]
[e-mail]
CASE NO. CV-11-06185-EMC
JOINT REQUEST TO APPEAR TELEPHONICALLY FOR INITIAL CASE MANAGEMENT
CONFERENCE AND [PROPOSED] ORDER

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Attorneys for Plaintiffs
Erin Tobin (CSB #234943)
Earthjustice
426 Seventeenth Street, 5th Floor
Oakland, CA 94612-2807
[phone] | Phone
[phone] | Fax
[e-mail]

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Local Counsel for Plaintiffs

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CASE NO. CV-11-06185-EMC
JOINT REQUEST TO APPEAR TELEPHONICALLY FOR INITIAL CASE MANAGEMENT
CONFERENCE AND [PROPOSED] ORDER

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[PROPOSED] ORDER

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Before the Court is the parties’ Joint Request To Appear Telephonically For

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Initial Case Management Conference And [Proposed] Order on September 28, 2012, at

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9:00 a.m. Upon due consideration, and for good cause shown, the parties’ request is

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hereby GRANTED. It is further ordered that

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Defendant’s counsel will be called at [phone] to participate in the hearing.

IT IS SO ORDERED.
24th
September
DATED this ______ day of ________________, 2012.

UNIT
ED

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NO

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S DISTRICT
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Court to call counsel between
9:00 and 10:30 a.m.

Counsel will be available from 9:00 am until the call occurs.

dwa
Judge E

________________________________
ERED
EDWARD M. CHEN ORD
IS SO
IT
I IED
United States District CourtFJudge
S MOD

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hen

rd M. C

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____ Plaintiffs’ counsel will be called at [phone] ext. 1020 and

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____________________________

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____ counsel will call the following number to participate in the hearing:

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D IS T IC T O
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CASE NO. CV-11-06185-EMC
JOINT REQUEST TO APPEAR TELEPHONICALLY FOR INITIAL CASE MANAGEMENT
CONFERENCE AND [PROPOSED] ORDER

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