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Sierra Club and Medical Advocates For Healthy Air v. Lisa P. Jackson

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO/OAKLAND DIVISION


June 21, 2012

SIERRA CLUB AND MEDICAL ADVOCATES FOR HEALTHY AIR, PLAINTIFFS,
v.
LISA P. JACKSON, IN HER OFFICIAL CAPACITY AS ADMINISTRATOR OF THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, AND JARED BLUMENFELD, IN HIS OFFICIAL CAPACITY AS REGIONAL ADMINISTRATOR FOR REGION IX OF THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, DEFENDANTS.

PAUL R. CORT, State Bar No. 184336 WENDY S. PARK, State Bar No. 237331 Earthjustice 50 California Street, Suite 500 3 San Francisco, CA 94111 pcort@earthjustice.org 4 wpark@earthjustice.org Tel: 415-217-2000 / Fax: 415-217-2040 5 Attorneys for Plaintiffs Sierra Club and 6 Medical Advocates for Healthy Air 7 8

JOINT STIPULATION TO EXTEND TIME FOR FILING MOTION FOR ATTORNEY'S FEES and [PROPOSED] ORDER

WHEREAS,

1. On March 26, 2012, this Court signed and entered a Consent Decree resolving plaintiffs' claims in this action (Dkt. 27); 23

2. Under the terms of the Consent Decree, plaintiffs' motion for attorney's fees and litigation costs is due on June 25, 2012, see id. ¶ 10; 25

3. The parties may stipulate to an extension of the time for filing plaintiffs' motion for attorney's fees and costs, see id. ¶ 4; 27

4. Plaintiffs and defendants have reached an agreement settling plaintiffs' claims for 28 attorney's fees and costs but need additional time to carry out the terms of the agreement;

5. An additional 91-day extension of the June 25, 2012 attorneys' fees and costs motion 2 deadline would afford the parties the time needed to do so without resort to further litigation; 3

THEREFORE, the parties, through their undersigned counsel, stipulate and request this Court 4 to order that plaintiffs shall serve and file a motion for attorney's fees and costs, if necessary, by 5 September 24, 2012. Defendants' counsel has authorized counsel for plaintiffs to sign and file this 6 stipulation jointly on the parties' behalf. 7 8

[PROPOSED] ORDER

costs, if necessary, by September 24, 2012. 4 5

IT IS SO ORDERED. Plaintiffs shall serve and file a motion for attorney's fees and litigation

UNITED STATES DISTRICT JUDGE

20120621

© 1992-2012 VersusLaw Inc.



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