FARM-TO-CONSUMER LEGAL DEFENSE FUND et al v. SCHAFER et al

Filing 36

Joint MOTION for Extension of Time to File Response/Reply as to 31 MOTION to Dismiss First Amended Complaint MOTION for Summary Judgment by ED SCHAFER, DON KOIVISTO (Attachments: # 1 Text of Proposed Order Entry and Order)(Riley, James)

BEFORE THE UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA Farm to Consumer Legal Defense Fund, et al. Plaintiffs, v U.S. Department of Agriculture, Tom Vilsack, Secretary and Michigan Department of Agriculture Director Don Koivisto Defendants. Case No. 1:08-cv-01546-RMC

DEFENDANTS' UNOPPOSED JOINT MOTION FOR FIRST EXTENSION OF TIME

Defendants jointly request that the Court grant them an extension of time from April 2, 2009 to April 22, 2009, to file their reply memoranda in support of Defendants' Motions to Dismiss Plaintiffs' First Amended Complaint. Plaintiffs' Oppositions are lengthy and are accompanied by numerous declarations and exhibits. The requested extension of time will enable Defendants to respond to Plaintiffs' contentions, and will assist the Court in ruling on the Motions to Dismiss. This is Defendants' first request for an extension of time to file their replies. The Court previously granted Plaintiffs' request for an extension of time to file their Oppositions to

Defendants' Motions to Dismiss. Plaintiffs have been consulted and do not oppose the requested extension. Respectfully submitted, Michael A. Cox Attorney General /s/ James E. Riley James E. Riley (P23992) First Assistant [e-mail] /s/ Danielle Allison-Yokom Danielle Allison-Yokom (P70950) Assistant Attorney General [e-mail] Attorneys for Defendant Don Koivisto, Michigan Department of Agriculture Environment, Natural Resources, and Agriculture Division 525 West Ottawa Street Lansing, MI 48913 [phone] /s/ Peter T. Wechsler Peter T. Wechsler Trial Attorney ­ US Department of Justice [e-mail] Civil Division ­ Federal Programs Branch 20 Massachusetts Avenue, NW Washington, DC 20530 Counsel for USDA

Dated: March 25, 2009

2