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Case3:13-cv-02265-JST Document64 Filed08/23/13 Page1 of 3




RONALD W. BEALS, Chief Counsel
DAVID GOSSAGE, Deputy Chief Counsel
LUCILLE Y. BACA, Assistant Chief Counsel (SBN 136282)
JANET WONG (SBN 124272)
STACY LAU (SBN 254507)
595 Market Street, Suite 1700, San Francisco, CA 94105
Telephone: (415) 904-5700, Facsimile: (415) 904-2333
[email protected]

Attorneys for Defendant MALCOLM DOUGHERTY






UNITED STATES DISTRICT COURT





NORTHERN DISTRICT OF CALIFORNIA




Case Number: 3:13-cv-02265-JST


STIPULATION RE: SCHEDULE FOR
DEFENDANTS’ MOTION FOR A STAY
OF PROCEEDINGS AND EXTENSION
OF TIME FOR DEFENDANTS TO
SERVE A RESPONSIVE PLEADING;
AND JOINT MOTION TO RESCHEDULE
THE CASE MANAGEMENT
CONFERENCE; [PROPOSED] ORDER


NATIVE SONGBIRD CARE AND
)
CONSERVATION, a non-profit organization;
)
VERONICA BOWERS, an individual;
)
MADRONE AUDUBON SOCIETY, a non-
)
profit corporation; CENTER FOR
)
BIOLOGICAL DIVERSITY, a non-profit
corporation; MARIN AUDUBON SOCIETY, a
)
non-profit corporation; and GOLDEN GATE
)
AUDUBON SOCIETY, a non-profit corporation,
)

)
)
)
)
)
)
)
)
)
)
)
)

ANTHONY FOXX, in his official capacity as
Secretary of United States Department of
Transportation; VICTOR MENDEZ, in his
official capacity as Administrator of the Federal
Highway Administration; and MALCOLM
DOUGHERTY, in his official capacity as Director
of the California Department of Transportation,



vs.


Plaintiffs,



Defendants.










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STIPULATION RE: SCHEDULE FOR DEFENDANTS’ MOTION FOR A STAY OF PROCEEDINGS AND
EXTENSION OF TIME FOR DEFENDANTS TO SERVE A RESPONSIVE PLEADING; AND JOINT MOTION
TO RESCHEDULE THE CASE MANAGMENT CONFERENCE; [PROPOSED] ORDER
Case 3:13-cv-02265-JST

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Case3:13-cv-02265-JST Document64 Filed08/23/13 Page2 of 3





Whereas Defendants intend to file a motion for a stay of proceedings in this matter for

reasons to be set forth in Defendants’ motion, the parties hereby stipulate to the following

briefing schedule and hearing date for Defendants’ motion for stay of proceedings:

1.

Defendants’ motion for a stay of proceedings will be filed and served on or before

August 30, 2013.

2.

Plaintiffs’ opposition brief will be filed and served 14 calendar days after

Defendants’ moving papers are filed.

3.

Defendants’ reply brief will be filed and served 7 calendar days after Plaintiffs’

opposition is filed.

4.

The hearing on Defendants’ motion for a stay of proceedings will be set for

October 3, 2013 at 2:00 p.m..



The parties further stipulate that the time for Defendants to file and serve responsive

pleadings to Plaintiffs’ First Amended Complaint (ECF No. 56), which are currently due on

August 23, 2013, shall be extended to a date to be set following the Court’s decision on

Defendants’ motion for a stay of proceedings.



In the interest of efficiency and judicial economy, and because the motion for a stay of

proceedings will impact scheduling in this case, the parties further propose and request that the

Case Management Conference, currently scheduled for September 4, 2013, be continued to the

date set for the hearing on Defendants’ motion, or to a date thereafter that the Court deems





appropriate.

DATED: August 21, 2013



DATED: August 21, 2013



DATED: August 21, 2013


































_/s/ Daniel Lutz____________________________
Attorney for Plaintiffs

_/s/ Jason A. Hill__________________________
Attorney for Federal Defendants

_/s/ Stacy J. Lau___________________________
Attorney for State Defendant

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STIPULATION RE: SCHEDULE FOR DEFENDANTS’ MOTION FOR A STAY OF PROCEEDINGS AND
EXTENSION OF TIME FOR DEFENDANTS TO SERVE A RESPONSIVE PLEADING; AND JOINT MOTION
TO RESCHEDULE THE CASE MANAGMENT CONFERENCE; [PROPOSED] ORDER
Case 3:13-cv-02265-JST

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Case3:13-cv-02265-JST Document64 Filed08/23/13 Page3 of 3







[PROPOSED] ORDER



The above stipulation is approved. In addition, the Case Management Conference,

currently scheduled for September 4, 2013, is continued to November 13, 2013 at 2:00 p.m.



IT IS SO ORDERED.









___________________________________________
JON S. TIGAR
United States District Judge










DATED: August 23, 2013





























STIPULATION RE: SCHEDULE FOR DEFENDANTS’ MOTION FOR A STAY OF PROCEEDINGS AND
EXTENSION OF TIME FOR DEFENDANTS TO SERVE A RESPONSIVE PLEADING; AND JOINT MOTION
TO RESCHEDULE THE CASE MANAGMENT CONFERENCE; [PROPOSED] ORDER
Case 3:13-cv-02265-JST

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