Sarah Uhlemann (WA Bar No. 41164)* Ignacia S. Moreno Cynthia Tuell (AZ Bar No. 025301)* Assistant Attorney General Center for Biological Diversity Kathryn M. Liberatore (NY Bar 4317780) P.O. Box 31001 Trial Attorney Seattle, WA 98103-9998 U.S. Department of Justice (206) 327-2344 Environment & Natural Resources Division firstname.lastname@example.org Natural Resources Section email@example.com P.O. Box 663 *Admitted pro hac vice Washington, DC 20044-0663 (202) 616-5082 Lisa T. Belenky (CA Bar No. 203225) Fax: (202) 305-0506 Justin Augustine (CA Bar No. 235561) firstname.lastname@example.org Center for Biological Diversity 351 California St., Suite 600 Attorneys for Defendants San Francisco, CA 94104 (415) 436-9682 x307 Fax: (415) 436-9683 email@example.com firstname.lastname@example.org Attorneys for Plaintiff
STIPULATION TO EXTEND TIME TO FILE PLAINTIFF'S MOTION TO AUGMENT THE RECORD
Pursuant to Local Rule 143, Plaintiff and Defendants in the above-captioned case, by and through their attorneys, have conferred and hereby STIPULATE as follows:
1. On October 20, 2010, Plaintiff initiated the instant litigation (Dkt. No. 1), and on January 4, 2011, Defendants filed their Answer (Dkt. No. 15).
2. Defendants lodged the Administrative Record on March 24, 2011. Dkt. No. 22.
3. On April 1, 2011, the Court set a Pretrial Schedule requiring Plaintiff to file any motion to augment the Administrative Record by this Friday, May 27, 2011. Dkt. No. 24.
4. On May 11, 2011, Plaintiff provided Defendants with a letter setting forth Plaintiff's concerns regarding the scope and content of the Record, and on May 20, 2011, Defendants provided a response.
5. Although parties have not yet reached an agreement as to the issues raised by Plaintiff, parties believe extending the current May 27, 2011 deadline for Plaintiff's motion to augment the Record may allow parties to resolve the remaining record issues without seeking relief from the Court.
In order to allow these discussions to continue and in the interest of judicial economy, parties stipulate to a nineteen-day extension for Plaintiff's motion.
6. Accordingly, parties stipulate to the following schedule for record-related briefing: Plaintiff's motion to augment the record will be due June 15, 2011;
Defendants' responsive brief regarding record augmentation will be due June 30, 2011;
Plaintiff's reply will be due July 8, 2011.
7. Prior to this request, parties had not sought any extensions of time regarding the motion to augment the Record, or for any other deadline set by the Court's April 1, 2011 Pretrial Schedule.