Bundorf et al v. Salazar et al

Filing 52

ORDER granting 50 Motion for Extension of Time and Revised Scheduling Order. Signed by Judge Miranda M. Du on 3/12/14. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:13-cv-00616-MMD-PAL Document 50 Filed 03/11/14 Page 1 of 3

ROBERT G. DREHER, Acting Assistant Attorney General
United States Department of Justice
Environment & Natural Resources Division
SETH M. BARSKY, Section Chief
S. JAY GOVINDAN, Assistant Section Chief
JAMES A. MAYSONETT, Senior 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,

No. 2: 13-cv-00616
UNOPPOSED MOTION FOR
EXTENSION OF TIME AND
REVISED SCHEDULING ORDER

Plaintiffs,
(First Request)
v.
S.M.R. JEWELL, Secretary of the Interior,
BUREAU OF LAND MANAGEMENT, U.S.
FISH & WILDLIFE SERVICE,
Defendants.
Federal Defendants S.M.R. Jewell, Secretary of the Interior, Bureau of Land
Management (“BLM”), and U.S. Fish and Wildlife Service (“FWS”) hereby request a four-week

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Case 2:13-cv-00616-MMD-PAL Document 50 Filed 03/11/14 Page 2 of 3

extension of time to file their opening summary judgment brief and for an Order revising the
briefing schedule for cross-motions for summary judgment, pursuant to Local Rules 6-1(b) and
6-2(a) and Judge Du’s Civil Standing Order. Undersigned counsel for Federal Defendants have
conferred with counsel for Defendant-Intervenor, who have indicated that they concur in the
revised schedule and do not oppose this motion. Counsel for Plaintiffs have indicated that they
do not oppose this motion, but that the proposed extension may result in Plaintiffs requesting
some extension of their revised Response deadline once their counsel’s schedule in April and
May becomes more clear.
Federal Defendants have not requested any previous extensions in this case. The Court
has granted one previous extension to Plaintiffs, at which time the Court entered a revised
scheduling order (ECF No. 33).
The extension requested in this motion is necessary due to counsel’s litigation obligations
in other cases, including Sierra Club v. Bostick, No. 13-cv-1239 (D. D.C.); Bettor Racing v.
NIGC, No. 13-cv-4051 (D. S.D.); Friends of the Wild Swan v. Jewell, No. 9:13-cv-00061-DWM
(D. Mont.). Granting this motion will not prejudice any party and will not affect any courtordered deadline aside from those set forth in the proposed revised briefing schedule below.
Accordingly, Federal Defendants respectfully request an extension of their deadline to crossmove for summary judgment, with that deadline and the subsequent deadlines to be revised as
follows:

Event

Current Deadline

Requested Extension

Federal Defendants’ (and Intervenor’s) crossmotion and response:

March 14, 2014

April 11, 2014

Plaintiffs’ response and reply:

April 4, 2014

May 2, 2014

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Case 2:13-cv-00616-MMD-PAL Document 50 Filed 03/11/14 Page 3 of 3

Federal Defendants’ (and Intervenor’s) reply:

April 25, 2014

May 23, 2014

For the foregoing reasons, Federal Defendants respectfully request that this Court grant
this unopposed motion.
Respectfully Submitted,
Robert G. Dreher
Acting Assistant Attorney General
United States Department of Justice
Environment & Natural Resources Division
Seth M. Barsky, Section Chief
S. Jay Govindan, Assistant Section Chief
James A. Maysonett, Senior Trial Attorney
Wildlife & Marine Resources Section
P.O. Box 7611, Washington D.C. 20044
[phone], facsimile [phone]
[e-mail]
/s/ Ty Bair
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
OF COUNSEL
Janell Bogue
Gregory Russell
Office of the Solicitor
U.S. Department of Interior
DATED: March 11, 2014

IT IS SO ORDERED.
March 11, 2014
Dated: _________________

______________________
U.S. District Judge

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