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Center For Biological v. U.S. Bureau of Land Management

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


June 29, 2011

CENTER FOR BIOLOGICAL
DIVERSITY, ET AL., PLAINTIFFS,
v.
U.S. BUREAU OF LAND MANAGEMENT, ET AL.,
DEFENDANTS.

The opinion of the court was delivered by: Susan Illston United States District Judge

Additional Counsel on Listed on Signature Pages

JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME FOR PLAINTIFFS TO FILE REQUEST FOR ATTORNEYS' FEES AND COSTS

1. The Court's Order Re: Remedy ("Order"), dated January 28, 2011, directed the parties to meet and confer regarding Plaintiffs' requests for attorneys' fees and costs and, if the parties were unable to resolve the requests, ordered Plaintiffs to submit any requests for attorneys' fees and costs within 60 days of the date of the Order.

2. On March 22, 2011, the Court granted the parties' stipulation and request to extend by 30 days Plaintiffs' deadline to submit any requests for attorneys' fees and costs.

3. On May 2, 2011, the Court granted the parties' stipulation and request to extend the deadline by an additional 60 days, up to and including June 27, 2011.

4. Plaintiffs have submitted to the Federal Defendants documentation supporting their requests for attorneys' fees and costs, and the parties continue to meet and confer in good faith in an effort to resolve the fees and costs issue as requested by the Court.

5. The parties now stipulate and request that the Court extend by an additional 30 days Plaintiffs' deadline to submit any requests for attorneys' fees and costs. If the Court grants this request for an extension of time, Plaintiffs would be required to submit to the Court any requests for attorneys' fees and costs by July 27, 2011.

Respectfully submitted this June 27, 2011.

SO STIPULATED:

Dated: June 27, 2011 MATTHEW BOSTICK (CA Bar No. 268563) David J. Lazerwitz (CA Bar No. 221349) Farella Braun & Martel LLP 235 Montgomery Street, 17th Floor San Francisco, CA 94104 Telephone: (415) 954-4400 Facsimile: (415) 954-4480 Email: mbostick@fbm.com Dated: June 27, 2011 /s/ Sky C. Stanfield SKY C. STANFIELD (CA Bar No. 244966) Keyes & Fox LLP 436 14th Street, Suite 1305 Oakland, CA 94612 Telephone: (510) 314-8204 Facsimile: (510) 225-3848 Email: sstanfield@keyesandfox.com Counsel for Plaintiffs Alliance for Responsible Recreation, The Wilderness Society, Friends of Juniper Flats, Western San Bernardino Landowners Association, the California Native Plant Society, and Community ORV Watch Dated: June 27, 2011 /s/ Lisa T. Belenky LISA T. BELENKY (CA Bar No. 203225) Center For Biological Diversity 351 California St., Suite 600 San Francisco, CA 94104 Telephone: (415) 436-9682 x 307 Facsimile: (415) 436-9683 Email: lbelenky@biologicaldiversity.org Attorneys for Plaintiffs Center for Biological Diversity, Sierra Club, Public Employees for Environmental Responsibility, and Desert Survivors Dated: June 27, 2011 /s/ Charles R. Shockey 9 CHARLES R. SHOCKEY (DC Bar No. 914879) U. S. Department of Justice Environment and Natural Resources Division Natural Resources Section 501 "I" Street, Suite 9-700 Sacramento, CA 95814-2322 Telephone: (916) 930-2203 Facsimile: (916) 930-2210 Email: charles.shockey@usdoj.gov Attorney for Federal Defendants, BLM, et al.

IT IS SO ORDERED. day extension to 7/18/11

20110629

© 1992-2011 VersusLaw Inc.



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