Free Motion for Extension of Time to File Answer - District Court of California - California

Case 3:07-cv-05075-CRB

Document 12

Filed 12/11/2007

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Plaintiffs, 20 v. 21 22 23 24 25 Defendants. 26 __________________________________________/ 27 28
Joint Stipulated Request C 07-05075 CRB

JACK SILVER, SBN 160575 Law Office of Jack Silver Post Office Box 5469 Santa Rosa, California 95402-5469 Telephone: (707) 528-8175 Facsimile: (707) 528-8675 lhm28843sbcglobal.net Attorney for Plaintiffs BRADFORD T. MCLANE U.S. Department of Justice Law & Policy Section Environment & Natural Resources Division P.O. Box 4390, Ben Franklin Station Washington, DC 20044-4390 Telephone: (202) 305-0544 Facsimile: (202) 514-4231 [email protected] Attorney for Defendants

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA NORTHERN CALIFORNIA RIVER WATCH, a non-profit corporation; ROBERT G. EVANS, SHERRY PETERSEN, DOUGLAS RAND EMERY, as individuals, Case No. C-07-05075 CRB JOINT STIPULATION FOR AN EXTENSION OF TIME TO FILE A RESPONSIVE PLEADING AND TO CONTINUE THE CASE MANAGEMENT CONFERENCE Date: Time: Ctrm: Judge: January 11, 2008 8:30 a.m. Courtroom 8, 19th Floor Hon. Charles R. Breyer

UNITED STATES DEPARTMENT OF THE INTERIOR, UNITED STATES FISH AND WILDLIFE SERVICE, UNITED STATES ARMY CORPS OF ENGINEERS,

Case 3:07-cv-05075-CRB

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Joint Stipulated Request C 07-05075 CRB

Plaintiffs Northern California River Watch, et al. ("Plaintiffs") and Defendants United States Department of the Interior, et al. ("Federal Defendants"), by and through their undersigned counsel, say as follows: WHEREAS, this action was filed on October 2, 2007; WHEREAS, the Court issued an order setting the initial Case Management Conference for Friday, January 11, 2008 at 8:30 a.m., and noting that otherwise, "the initial case management scheduling order shall remain the same"; WHEREAS, under Federal Rule of Civil Procedure 12(a)(3)(A), the United States is to serve an answer to a complaint within 60 days after the United States Attorney is served; WHEREAS, Plaintiffs served their complaint in this action on the U.S. Attorney's office for the Federal District Court for the Norther District of California on October 19, 2007 and therefore Federal Defendants' responsive pleading is currently due by December 18, 2007. WHEREAS, there have been no previous extensions of time for Federal Defendants

to file and serve a responsive pleading;
WHEREAS, the parties would like an opportunity to explore the possibility of a stipulated dismissal of this action; WHEREAS, Plaintiffs' counsel have consented to an extension of time of thirty (30) days, until January 17, 2008: IT IS HEREBY STIPULATED by and between counsel for plaintiffs and defendants that Federal Defendants shall file a responsive pleading by January 17, 2008. IT IS HEREBY STIPULATED by and between counsel for plaintiffs and defendants that the last day to file the rule 26(f) Report and the joint Case Management Statement may be continued, court permitting, to Friday, February 15, 2008. IT IS HEREBY STIPULATED by and between counsel for plaintiffs and defendants that the Case Management Conference scheduled for January 11, 2007, may be continued, court permitting, to Friday, February 22, 2007 at 8:30 a.m.

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Joint Stipulated Request C 07-05075 CRB

Respectfully submitted,

Dated __12/11/2007__________

________/s/___________ JACK SILVER Attorney for Plaintiffs NORTHERN CALIFORNIA RIVER WATCH, ROBERT G. EVANS, DOUGLAS RAND EMERY ________/s/___________ BRADFORD T. MCLANE U.S. Department of Justice Environment & Natural Resources Division Attorney for Defendants UNITED STATES DEPARTMENT OF THE INTERIOR, UNITED STATES FISH AND WILDLIFE SERVICE, UNITED STATES ARMY CORPS OF ENGINEERS

Dated __12/11/2007__________

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