The Republic of the Marshall Islands v. The United States of America et al

Filing 22

ORDER GRANTING AS MODIFIED 21 STIPULATION TO SET BRIEFING SCHEDULE AND TO RESET CASE MANAGEMENT CONFERENCE. Signed by Judge JEFFREY S. WHITE on 6/11/14. (jjoS, COURT STAFF) (Filed on 6/11/2014)

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STUART F. DELERY
Assistant Attorney General
ANTHONY J. COPPOLINO
Deputy Branch Director
ERIC R. WOMACK
(IL Bar No. 6279517)
Trial Attorney
Civil Division, Federal Programs Branch
U.S. Department of Justice
P.O. Box 883
Washington, D.C. 20044
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Counsel for Defendants

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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THE REPUBLIC OF THE MARSHALL
ISLANDS,

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Plaintiff,

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v.

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THE UNITED STATES OF AMERICA, et al.,
Defendants.

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Case No. 3:14-cv-01885-JSW
Stipulation to Set Briefing Schedule
and to Reschedule the Case
Management Conference
and Order Thereon as Modified

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The parties agree to extend the time for Defendants to respond to the Complaint and to

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set a briefing schedule for a motion filed pursuant to Federal Rule of Civil Procedure 12. The

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parties also agree, pursuant to this Court’s approval, to reschedule the case management

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conference, currently scheduled for August 1, 2014. In support thereof, the parties state as
follows:
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Defendants’ response to Plaintiff’s Complaint is currently due on July 11, 2014.

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Stipulation, Case No. 3:14-cv-01885-JSW

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2.

The Deputy Branch Director that is responsible for supervision of this case on

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behalf of the federal Defendants will be out of the office on July 11 due to previously-scheduled

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travel plans. Accordingly, Defendants request a short extension of 10 days to allow for the

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review and completion of the Defendants’ response to the Complaint.

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3.

The parties have also consulted and agreed upon a schedule for the filing of

memoranda in the event that Defendants file a motion pursuant to Federal Rule of Civil

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Procedure 12 that would allow counsel sufficient time to consult with their clients and prepare

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said memoranda. Assuming the filing of such a motion, the schedule would proceed as follows:

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Defendants’ Rule 12 Motion

July 21, 2014

Plaintiffs’ Opposition

August 21, 2014

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Defendants’ Reply

September 8, 2014

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4.

This proposed briefing schedule would not affect any established deadlines.

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5.

The Case Management Conference in this matter has been set for August 1, 2014.

6.

Undersigned counsel for the federal Defendants will be on previously-scheduled

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leave on August 1, 2014 and August 8, 2014. Therefore, counsel for Defendants will be

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unavailable on those dates. Accordingly, and to fully accommodate the proposed briefing

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schedule set forth above, the parties respectfully request to reschedule the Case Management

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Conference for September 12, 2014, or a time thereafter that is convenient for the Court.

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Dated: June 11, 2014

Respectfully submitted,
STUART F. DELERY
Assistant Attorney General

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ANTHONY J. COPPOLINO
Deputy Branch Director

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Stipulation, Case No. 3:14-cv-01885-JSW

/s/ Eric R. Womack
ERIC R. WOMACK
(IL Bar No. 6279517)
Trial Attorney
Civil Division, Federal Programs Branch
U.S. Department of Justice
P.O. Box 883
Washington, D.C. 20044
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Counsel for Defendants

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/s/ Laurie B. Ashton (by permission)
Laurie B. Ashton (Admitted pro hac vice)
Gary A. Gotto (Admitted pro hac vice)
[e-mail]
[e-mail]
3101 North Central Avenue, Suite 1400
Phoenix, AZ 85012
[phone], Fax [phone]

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Counsel for Plaintiff

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The Court shall set a case management conference, if necessary, in its order resolving the motion to dismiss.
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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June 11,
Dated: _______ 2014

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____________________________________
Hon. JEFFREY S. WHITE
United States District Judge

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Stipulation, Case No. 3:14-cv-01885-JSW