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

Filing 42

Supplemental MOTION for Leave to File Supplement to the Administrative Record by DAN NOLT, GREG NIEWENDORP, FARM-TO-CONSUMER LEGAL DEFENSE FUND, ROBERT ALEXANDER, JOE GOLIMBIESKI, ROBERT KEYWORTH, GLEN MAST, ANDREW SCHNEIDER, ROSEANNE WYANT (Attachments: # 1 Memorandum in Support, # 2 Exhibit A - List of Proposed Supplemental Record Items, # 3 Exhibit B - Collagenex Pharmaceuticals v Thompson)(Cox, David)

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

Doc. 42

BEFORE THE UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA Farm-to-Consumer Legal Defense Fund, et al. Plaintiffs v. U.S. Department of Agriculture, et al. Defendants : : : : : : : : : : Case No. 1:08-cv-01546-RMC Judge Rosemary M. Collyer

PLAINTIFFS' MOTION FOR LEAVE TO FILE SUPPLEMENT TO THE ADMINISTRATIVE RECORD Plaintiffs move the Court for leave to supplement the administrative record that was filed by Defendant United States Department of Agriculture ("USDA") on December 16, 2008. This is a motion pursuant to Fed.R.Civ.Proc. 7(b). Concurrence for this motion was requested but was not received. The motion will serve the Court's interest in efficiency and economy pursuant to Fed.R.Civ.Proc. 1. A memorandum in support is attached hereto and incorporated by reference as if rewritten herein. Dated: May 2, 2009 Respectfully submitted, /s/ David G. Cox David G. Cox (D.C. Bar No. OH 0020) 4240 Kendale Road Columbus, OH 43220 [e-mail] Phone: [phone] Counsel for Plaintiffs

Dockets.Justia.com

CERTIFICATE OF SERVICE I hereby certify that on May 2, 2009, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to the following: Peter T. Wechsler [e-mail] Trial Attorney United States Department of Justice Civil Division Federal Programs Branch 20 Massachusetts Avenue, N.W. Washington, D.C. 20530 Counsel for USDA and James E. Riley [e-mail] First Assistant Danielle Allison-Yokom [e-mail] Assistant Attorney General Michigan Department of Agriculture Environment, Natural Resources and Agriculture Division 525 West Ottawa Street 6th Floor Williams Building Lansing, MI 48913 Counsel for MDA

/s/ David G. Cox David G. Cox

2