BENJAMIN B. WAGNER United States Attorney J. EARLENE GORDON Assistant United States Attorneys 501 I Street, Suite 10-100 Sacramento, CA 95814 Telephone: (916) 554-2700 Facsimile: (916) 554-2900 Attorneys for Defendant Bureau of Land Management
STIPULATION TO AMEND THE STATUS (PRETRIAL SCHEDULING) ORDER;
Plaintiffs Western Watersheds Project and Wild Earth Guardians, and Defendant Bureau of Land Management, by and through their respective counsel, and pursuant to Local Rule 143 hereby stipulate to an amendment to the Court's Status (Pretrial Scheduling) Order entered herein on April 25, 2011, [Doc. 22], to allow Defendant an additional twenty-eight (28) days to and until July 19, 2011, within which to file the Administrative Record, and further to allow Plaintiffs an additional twenty-eight (28) days to and until August 16, 2011, to review the record and determine whether supplementation of the record is necessary, all as set forth more fully below.
1. The current Administrative Record is currently due to be filed on June 21, 2011. Plaintiffs have until July 21, 2011, within which to review the record and make any request for supplementation. [Doc. 22, Section IV]
2. No prior extensions of time have been sought.
3. The proposed amendment will not affect any other deadlines in the case. A status conference was originally set for July 27, 2011. The Court has ordered that status conference to be reset for August 24, 2011. There are currently no other deadlines in this case, and the proposed extension will still result in the parties' accomplishment of these tasks prior to the date of the follow-up status conference.
4. The undersigned Assistant United States Attorney represents that she has been unavailable, for a number of weeks, to assist in the preparation and filing of the Administrative Record due to a family health emergency, as set forth in the Declaration attached hereto as Exhibit
A. She has recently returned to the office, and after consulting with the agency believes that the four-week extension of time proposed will be sufficient to properly prepare and file a complete Administrative Record herein.
5. Because of the later filing of the Administrative Record, Plaintiffs' counsel will need a (28) day extension of time within which to review the record, and make any request they deem necessary for supplementation.
For the foregoing reasons, the parties stipulate to an amendment of the Status (Pretrial Scheduling) Order [Doc. 22] allowing Defendant until July 19, 2011, within which to file the Administrative Record herein, and allowing Plaintiff until August 16, 2011, within which to request any supplementation thereto.
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