Center for Biological Diversity et al v. U.S. Fish & Wildlife Service et al

Filing 84

STIPULATION AND ORDER re 83 STIPULATION WITH PROPOSED ORDER Requesting Extension of Time to File Motion for Attorneys' Fees filed by Center for Biological Diversity, Environmental Protection Information Center. Signed by Judge Jon S. Tigar on January 31, 2018. (wsn, COURT STAFF) (Filed on 1/31/2018)

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STACEY P. GEIS (CA Bar No. 181444)
[e-mail]
GREGORY C. LOARIE (CA Bar No. 215859)
[e-mail]
EARTHJUSTICE
50 California Street, Suite 500
San Francisco, CA 94111
Tel: [phone]
Fax: [phone]

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Counsel for Plaintiffs

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
CENTER FOR BIOLOGICAL DIVERSITY, et al., )
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Plaintiffs,
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vs.
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U.S. FISH & WILDLIFE SERVICE, et al.,
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Defendants,
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and
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SISKIYOU COUNTY, et al.,
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Defendant Intervenors.
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Case No.: 3:15-cv-05754-JST
THIRD STIPULATED REQUEST
TO EXTEND TIME TO FILE
MOTION FOR ATTORNEYS’ FEES
and
[PROPOSED] ORDER
(Civ. L.R. 6-2)

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WHEREAS, by stipulated order dated December 4, 2017 (ECF Doc. 82), the deadline for

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Plaintiffs to file a motion for attorneys’ fees and costs in this case is currently February 23, 2018;

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WHEREAS, Plaintiffs and Defendants have exchanged written offers of settlement;

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WHEREAS, Plaintiffs and Defendants require additional time to continue their good faith

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settlement negotiations;
WHEREAS, if Plaintiffs and Defendants reach an agreement in principle, the extension

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proposed below would enable them to draft settlement documents and obtain the necessary

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approvals from officials within the Department of Justice and the Department of Interior;
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Third Stipulated Request to Extend Time to File Motion for Attorneys’ Fees – No. 3:15-cv-05754-JST

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NOW, THEREFORE, the parties, by and through their undersigned counsel of record,

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stipulate and request that the February 23, 2018, deadline for Plaintiffs to file a motion for an award

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of fees and costs under 16 U.S.C. § 1540(g)(4) be extended by 60 days, to April 24, 2018.
Respectfully submitted,

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STACEY P. GEIS (CA Bar No. 181444)
[e-mail]

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Dated: Jan. 31, 2018

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/s/ Gregory C. Loarie
GREGORY C. LOARIE
[e-mail]
EARTHJUSTICE
50 California Street, Suite 500
San Francisco, CA 94111
Tel: [phone] / Fax: [phone]
Attorneys for Plaintiffs

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JEFFREY H. WOOD
Acting Assistant Attorney General
SETH M. BARSKY, Chief
MEREDITH L. FLAX, Assistant Chief

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Dated: Jan. 31, 2018

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/s/ Nicole M. Smith
NICOLE M. SMITH, Trial Attorney
U.S. Department of Justice
Environment & Natural Resources Division
Wildlife & Marine Resources Section
Ben Franklin Station, P.O. Box 7611
Washington, D.C. 20044-7611
Tel: [phone] / Fax: [phone]
Email: [e-mail]

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Attorneys for Federal Defendants

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Dated: Jan. 31, 2018

/s/ Lawson E. Fite
Lawson E. Fite (Ore. Bar #055573)
Pro Hac Vice
American Forest Resource Council
5100 S.W. Macadam, Suite 350
Portland, Oregon 97239
Tel: [phone] / Fax: [phone]
[e-mail]
Attorney for Defendant-Intervenors

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Third Stipulated Request to Extend Time to File Motion for Attorneys’ Fees – No. 3:15-cv-05754-JST

[PROPOSED] ORDER

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Pursuant to stipulation, IT IS SO ORDERED. The deadline for Plaintiffs to file a motion for

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an award of attorneys’ fees and other expenses under 16 U.S.C. § 1540(g)(4) is extended to April 24,

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2018.

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Dated: January 31, 2018

Hon. Jon S. Tigar
United States District Court Judge

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Third Stipulated Request to Extend Time to File Motion for Attorneys’ Fees – No. 3:15-cv-05754-JST