FRIENDS OF THE RIVER, DEFENDERS OF WILDLIFE, and CENTER FOR BIOLOGICAL DIVERSITY, Plaintiffs,
UNITED STATES ARMY CORPS OF ENGINEERS, et al., Defendants.
Robert G. Dreher, Acting Assistant Attorney General, Devon Lehman McCune, Trial Attorney, John H. Martin, Trial Attorney, U.S. Department of Justice, Environment and Natural Resources Division, Denver, CO, Attorneys for Defendants.
John H. Martin, Trial Attorney, U.S. Department of Justice, Environment and Natural Resources Division, Wildlife and Marine Resources Section, Denver, CO, Attorneys for Defendants.
Jason Rylander (Pro hac vice), Defenders of Wildlife, Washington D.C., E. Robert Wright (CA Bar No 51861), Senior Counsel, Sacramento, California, Lisa T. Belenky (CA Bar No. 203225), D. Adam Lazar (CA Bar No. 237485), Center for Biological Diversity, San Francisco, CA, Attorneys for Plaintiffs.
STIPULATION AND PROPOSED ORDER FOR CONTINUANCE OF MOTION HEARING
ALLISON CLAIRE, Magistrate Judge.
Pursuant to stipulation, L.R. 143 and 251, and the Court's August 5, 2013 Order (Doc. No. 75), the parties, by and through their undersigned counsel, hereby request a fourteen day continuance, from August 21, 2013, to September 4, 2013, of the hearing before Magistrate Judge Allison Claire on Plaintiffs' motion to compel production of the administrative record as presented in the Fourth Joint Status Report. In support of their request, the parties hereby state as follows:
1. In the time since the Court's August 5, 2013, order (Doc. No. 75) setting the motion to compel for hearing on August 21, 2013, counsel for the parties have had several productive discussions regarding Plaintiffs' issues with the Administrative Record, Defendants' responses, and options to resolve those differences.
2. The parties seek this continuance to allow them additional time to confer and attempt to resolve their differences. As the parties' discussions have proceeded, they have been able to more specifically identify their concerns with the Administrative Record and additional options for proceeding. This requested extension will permit the parties to confer further about resolving their differences and also enable the parties to submit, if finally necessary, a Joint Statement re Discovery Disagreement that explains the basis for the parties' remaining differences with greater precision.
Accordingly, in order to allow counsel additional time to confer about their differences regarding the Administrative Record, the parties request a two week continuance until September 4, 2013, of the hearing before Magistrate Judge Allison Claire on Plaintiffs' motion to compel production ...