Center For Biological Diversity et al v. United States Environmental Protection Agency et al

Filing 15

ORDER GRANTING 14 STIPULATION to Extend Deadline for Answer, Continue Case Management Conference filed. Answer due by 7/18/2016. Joint Case Management Statement due by 7/27/2016. Initial Case Management Conference set for 8/3/2016 02:30 PM. Signed by Judge Saundra Brown Armstrong on 6/1/16. (jjoS, COURT STAFF) (Filed on 6/2/2016)

Case 4:16-cv-01946-SBA Document 14 Filed 06/01/16 Page 1 of 3

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JOHN C. CRUDEN
Assistant Attorney General
Environment & Natural Resources Division

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DEBRA J. CARFORA
Trial Attorney

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United States Department of Justice
Environmental Defense Section

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P.O. Box 7611
Washington, D.C. 20044-7611
Tel: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Defendant

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[Additional counsel listed on signature page]

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

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Case No. 4:16-cv-1946-SBA

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CENTER FOR BIOLOGICAL
DIVERSITY, et al.,
Plaintiffs,
v.

JOINT STIPULATION TO EXTEND
DEADLINE FOR ANSWER,
CONTINUE CASE MANAGEMENT
CONFERENCE AND [PROPOSED]
ORDER

THE UNITED STATES
ENVIRONMENTAL PROTECTION
AGENCY, et al.,

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Defendants.

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Pursuant to Civil L.R. 6-2, Plaintiffs Center for Biological Diversity, Sierra Club,

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Association of Irritated Residents, and Climate Change Law Foundation, and Defendants,

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the United States Environmental Protection Agency, Gina McCarthy in her official

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capacity as the Administrator of the United States Environmental Protection Agency, and

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Jared Blumenfeld in his official capacity as Regional Administrator of the United States
JOINT STIPULATION
CASE NO. 4:16-cv-1946-SBA

Case 4:16-cv-01946-SBA Document 14 Filed 06/01/16 Page 2 of 3

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Environmental Protection Agency (collectively “EPA”), hereby stipulate to and request

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an order continuing the case management conference currently scheduled for July 13,

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2016 and extending the deadline for Defendants’ Answer to July 18, 2016. In support of

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this stipulation, the parties state the following:

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The Court entered an order setting this matter for a case management conference

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at 2:30 PM on July 13, 2016. ECF No. 6. Subsequently, on May 27, 2016, the parties

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had an initial meet and confer concerning this case.

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The requested extension will allow EPA enough time to properly examine

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whether the parties may be able to resolve this case without dispositive motions or a trial.

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Meanwhile, the parties will continue to confer concerning this case.

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The parties have not previously requested any extensions in this case.

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Therefore, in light of the fact that parties may be able to resolve this case without

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the need for dispositive motions or a trial, the parties stipulate to and request an order

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continuing the case management conference until 2:30 PM on August 3, 2016; continuing

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the last day to file either Stipulation to ADR Process or Notice of Need for ADR Phone

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Conference to July 20, 2016; continuing the last day to file Rule 26(f) Reports, complete

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initial disclosures or state objection in Rule 26(f) Report, and file Case Management

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Statements to July 27, 2016; and extending the answer due date to July 18, 2016.

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Respectfully submitted,

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Date: June 1, 2016

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JOHN C. CRUDEN
Assistant Attorney General
Environment and Natural Resources Division
/s/ Debra J Carfora
DEBRA J. CARFORA
Trial Attorney
United States Department of Justice
Environmental Defense Section
P.O. Box 7611
Washington, D.C. 20044-7611
Tel: [phone]
Fax: [phone]
[e-mail]
JOINT STIPULATION
CASE NO. 4:16-cv-1946-SBA

Case 4:16-cv-01946-SBA Document 14 Filed 06/01/16 Page 3 of 3

Attorneys for Defendant

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Date: June 1, 2016

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/s/ James M. Birkelund
JAMES M. BIRKELUND, Cal. Bar No.206328
Climate Change Law Foundation
548 Market St., #11200
San Francisco, CA 94104
[e-mail]
Tel: [phone]; Fax: [phone]

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Attorney for Plaintiffs Climate Change Law
Foundation and Association of Irritated Residents

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/s/ Maya Golden-Krasner
MAYA GOLDEN-KRASNER, Cal. Bar No.
217557
The Center for Biological Diversity
P.O. Box 1476
La Canada Flintridge, CA 91012
[e-mail]
Tel: [phone]; Fax: [phone]
Attorney for Plaintiff Center for Biological
Diversity

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/s/ Elizabeth Benson
ELIZABETH BENSON, Cal. Bar No. 268851
Sierra Club
2101 Webster Street, Suite 1300
Oakland, CA 94612
[e-mail]
Tel: [phone]; Fax: [phone]

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Attorney for Plaintiff Sierra Club

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JOINT STIPULATION
CASE NO. 4:16-cv-1946-SBA

Case 4:16-cv-01946-SBA Document 14-1 Filed 06/01/16 Page 1 of 1

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[PROPOSED] ORDER

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Pursuant to Stipulation, IT IS ORDERED that the deadline for Defendant’s

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Answer is hereby extended to July 18, 2016 and the Case Management Conference is

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continued until 2:30 PM on August 3, 2016.

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1st
June
DATED this ______ day of ___________, 2016.

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________________________________
SAUNDRA BROWN ARMSTRONG
United States District Judge

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JOINT STIPULATION
CASE NO. 4:16-cv-1946-SBA