SF Bay Conservation and Development Commission v. United States Army Corps of Engineers et al

Filing 67

STIPULATION AND ORDER RE 66 for Extension of Time to File Response/Reply and to Reschedule the Hearing on the Motion. Signed by Judge Richard Seeborg on 4/19/18. (cl, COURT STAFF) (Filed on 4/20/2018)

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JEFFREY H. WOOD
Acting Assistant Attorney General
U.S. Department of Justice
Environment & Natural Resources Section
NORMAN L. RAVE, JR. (D.C. Bar No. 431602)
Environmental Defense Section
JACQUELINE M. LEONARD (NY Bar No. 5020474)
Natural Resources Section
P.O. Box 7611
Ben Franklin Station
Washington, D.C. 20044-7611
Tel: [phone]
[phone]
Email: [e-mail]
[e-mail]

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Attorneys for Defendants
Additional counsel listed on following page
UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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SAN FRANCISCO BAY CONSERVATION,
AND DEVELOPMENT COMMISSION,

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Plaintiff,

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and

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SAN FRANCISCO BAYKEEPER,
Plaintifff-Intervenor,
v.

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UNITED STATES ARMY CORPS OF
ENGINEERS, et al.,
Defendant.

No. 3:16-cv-05420-RS
STIPULATION TO EXTEND
DEADLINE FOR PLAINTIFFS’
REPLY ON MOTION TO COMPLETE
AND/OR SUPPLEMENT THE
ADMINISTRATIVE RECORD,
TO RESCHEDULE THE HEARING
ON THE MOTION, AND [PROPOSED]
ORDER

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XAVIER BECERRA
Attorney General of California
DAVID G. ALDERSON
Supervising Deputy Attorney General
TARA L. MUELLER (State Bar No. 161536)
Deputy Attorney General
1515 Clay Street, 20th Floor
P.O. Box 70550
Oakland, CA 94612-0550
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
MARC A. ZEPPETELLO (State Bar No. 121185)
Chief Counsel
SAN FRANCISCO BAY CONSERVATION AND DEVELOPMENT COMMISSION
455 Golden Gate Avenue, Suite 10600
San Francisco, CA 94102
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiff San Francisco Bay Conservation and Development Commission
ERICA A. MAHARG (State Bar No. 279396)
NICOLE C. SASAKI (State Bar No. 298736)
M. BENJAMIN EICHENBERG (State Bar No. 2790893)
SAN FRANCISCO BAYKEEPER, INC.
1736 Franklin Street, Suite 800
Oakland, California 94612
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]

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Attorneys for Plaintiff-Intervenor San Francisco Baykeeper

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Stipulation to Extend Deadline for Plaintiffs’ Reply on Motion to Complete and/or Supplement
the Administrative Record, to Reschedule the Hearing on the Motion, and [Proposed] Order
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The parties hereby stipulate to and request that the Court enter the attached Proposed

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Order extending the deadline for Plaintiff and Plaintiff-Intervenor’s Reply to Defendants’

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Response to their Motion to Complete and/or Supplement the Administrative Record and

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rescheduling the hearing on that motion.

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1. Pursuant to the Court’s Order of October 26, 2017 (ECF No. 62), Plaintiff and
Plaintiff-Intervenor jointly filed a Motion to Complete and/or Supplement the Administrative
Record (ECF No. 64) on March 16, 2018, and Defendants filed their Response (ECF No. 65) on
April 16, 2018. Plaintiff and Plaintiff-Intervenor’s Reply is currently due April 30, 2018, and the
hearing on the motion is scheduled for May 17, 2018. ECF No. 62.

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2. Due to a scheduling conflict, counsel for Defendants is unable to attend the scheduled
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hearing on May 17. The parties have agreed to request that the Court reschedule the hearing for
June 21, 2018 at 1:30 p.m.
3. The parties have also agreed to extend the deadline for Plaintiff and PlaintiffIntervenor’s Reply to Defendants’ Response to the Motion to Complete and/or Supplement the
Administrative Record to May 7, 2018.
4. Accordingly, the parties jointly stipulate and request that the Court enter the attached

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Proposed Order providing that the May 17, 2018 hearing is rescheduled to June 21, 2018, and

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that the deadline for Plaintiff and Plaintiff-Intervenor’s Reply to Defendants’ Response is

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extended to May 7, 2018.

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Dated: April 19, 2018
Respectfully submitted,

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UNITED STATES DEPARTMENT OF JUSTICE

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JEFFREY H. WOOD

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/s/ Jacqueline M. Leonard
JACQUELINE M. LEONARD
Attorney for Defendants
Stipulation to Extend Deadline for Plaintiffs’ Reply on Motion to Complete and/or Supplement
the Administrative Record, to Reschedule the Hearing on the Motion, and [Proposed] Order
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SAN FRANCISCO CONSERVATION & DEVELOPMENT
COMMISSION
XAVIER BECCERA
Attorney General of California

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/s/ Tara L. Mueller
TARA L. MUELLER
Deputy Attorney General
Attorney for Plaintiff

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SAN FRANCISCO BAYKEEPER
/s/ Erica A. Maharg
ERICA A. MAHARG
Managing Attorney
Attorney for Plaintiff-Intervenor

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Stipulation to Extend Deadline for Plaintiffs’ Reply on Motion to Complete and/or Supplement
the Administrative Record, to Reschedule the Hearing on the Motion, and [Proposed] Order
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[PROPOSED] ORDER
Pursuant to stipulation, IT IS SO ORDERED. The hearing on Plaintiff and PlaintiffIntervenor’s motion to complete and/or supplement the administrative record in this case is
rescheduled to June 21, 2018 at 1:30 p.m., and Plaintiff and Plaintiff-Intervenor shall file any

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reply to Defendants’ opposition by May 7, 2018.

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Date: 4/19/18

___________________________
Hon. Richard G. Seeborg
United States District Judge

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Stipulation to Extend Deadline for Plaintiffs’ Reply on Motion to Complete and/or Supplement
the Administrative Record, to Reschedule the Hearing on the Motion, and [Proposed] Order
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