Bundorf et al v. Salazar et al

Filing 104

ORDER Granting 103 Motion to Extend Time to Respond/Reply re 99 MOTION to Vacate; 100 MOTION for Permanent Injunction; and 101 MOTION Clarification of Order. Responses due by 3/26/2015. Replies due by 4/17/2015. Signed by Judge Miranda M. Du on 3/13/15. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:13-cv-00616-MMD-PAL Document 103 Filed 03/12/15 Page 1 of 4

JOHN C. CRUDEN, Assistant Attorney General
United States Department of Justice
Environment & Natural Resources Division
SETH M. BARSKY, Section Chief
S. JAY GOVINDAN, Assistant Section Chief
JEREMY HESSLER, Trial Attorney
Wildlife & Marine Resources Section
P.O. Box 7611, Washington D.C. 20044
[phone], facsimile [phone]
[e-mail]
MAUREEN E. RUDOLPH, Senior Trial Attorney
TY BAIR, Trial Attorney
Natural Resources Section
P.O. Box 7611, Washington, D.C. 20044-7611
[phone], facsimile [phone]
COUNSEL FOR FEDERAL DEFENDANTS
Attorneys for the Federal Defendants

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA

JUDY BUNDORF, an individual; FRIENDS OF
SEARCHLIGHT DESERT AND MOUNTAINS;
BASIN AND RANGE WATCH; ELLEN ROSS,
an individual; and RONALD VAN FLEET, SR.,
an individual,
Plaintiffs,

No. 2: 13-cv-00616
UNOPPOSED MOTION FOR
EXTENSION OF TIME
(Second Request)

v.
S.M.R. JEWELL, Secretary of the Interior,
BUREAU OF LAND MANAGEMENT, U.S.
FISH & WILDLIFE SERVICE,
Defendants.
Pursuant to Local Rules 6-1(b) and 6-2(a) and Judge Du’s Civil Standing Order, Federal
Defendants S.M.R. Jewell, Secretary of the Interior, Bureau of Land Management (“BLM”), and

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Case 2:13-cv-00616-MMD-PAL Document 103 Filed 03/12/15 Page 2 of 4

U.S. Fish and Wildlife Service (“FWS”) hereby request an extension of time to file their points
and authorities in response to Plaintiffs’ Motion to Vacate (ECF No. 99), Motion for Permenent
Injunction (ECF No. 100), and Motion for Clarification of Order (ECF No. 101), revising the
briefing schedule to reflect the response will be due March 26, 2015. Intervenor-Defendant
requests an equivalent extension to March 26, 2015 for its response to Plaintiffs’ motions.
Finally, Plaintiffs request an extension to April 17, 2015 to file their reply brief. Undersigned
counsel for Federal Defendants have conferred with counsel for Defendant-Intervenor and for
Plaintiffs, who have indicated that they concur in the revised schedule and do not oppose this
motion.
Federal Defendants have requested one previous extension in this case for a prior
summary judgment brief deadline, which Intervenor-Defendant joined and which the Court
granted. (ECF Nos. 50, 52). The Court has granted three previous extensions to Plaintiffs on
prior deadlines, including an extension of their deadlines to response to Federal Defendants’
Cross-Motion for Summary Judgment and Motion to Strike. (See ECF Nos. 33, 69), as well as a
Motion to Extend Time to File Bill of Costs (ECF No. 92).
The extension requested in this motion is necessary due to counsel’s litigation obligations
in other cases, including Friends of Animals v. Jewell, No. 15-cv-0016 (D. D.C.); Bishop v.
Bostick, No. 13-cv-0082 (N.D. Tex.) and No Casino in Plymouth v. Jewell, No. 12-cv-1748 (E.D.
Cal.). Granting this motion will not prejudice any party and will not affect any subsequent courtordered deadlines.

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Case 2:13-cv-00616-MMD-PAL Document 103 Filed 03/12/15 Page 3 of 4

Accordingly, Federal Defendants respectfully request that the upcoming deadlines be
revised as follows:

Event

Current Deadline Requested Extension

Federal Defendants’ and DefendantIntervenor’s response to Plaintiffs’ motions
(ECF Nos. 99-101):

March 18, 2015

March 26, 2015

Plaintiffs’ reply in support of motions (ECF
Nos. 99-101):

March 25, 2015

April 17, 2015

For the foregoing reasons, Federal Defendants respectfully request that this Court grant
this unopposed motion.
Respectfully Submitted,
John C. Cruden, Assistant Attorney General
United States Department of Justice
Environment & Natural Resources Division
Seth M. Barsky, Section Chief
S. Jay Govindan, Assistant Section Chief
/s/ Jeremy Hessler
Jeremy Hessler, Trial Attorney
Wildlife & Marine Resources Section
P.O. Box 7611, Washington D.C. 20044
[phone], facsimile [phone]
[e-mail]
Maureen E. Rudolph, Senior Trial Attorney
Ty Bair, Trial Attorney
Natural Resources Section
P.O. Box 7611, Washington, D.C. 20044-7611
[phone], facsimile [phone]
Counsel for Federal Defendants
Attorneys for the Federal Defendants

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Case 2:13-cv-00616-MMD-PAL Document 103 Filed 03/12/15 Page 4 of 4

OF COUNSEL
Janell Bogue
Gregory Russell
Office of the Solicitor
U.S. Department of Interior
DATED: March 12, 2015

IT IS SO ORDERED:

___________________________
Miranda M. Du
United States District Judge
March 13, 2015

DATED: _______________________

2:13-cv-616-MMD-

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