Opinion
Case No.: 3:11-cv-01310-SC
10-14-2011
CENTER FOR FOOD SAFETY, BEYOND PESTICIDES, CORNUCOPIA INSTITUTE, CALIFORNIA FARMERS UNION, DAKOTA RESOURCES COUNCIL, GEERTSON SEED FARMS, NATIONAL FAMILY FARM COALITION, NORTHEAST ORGANIC DAIRY PRODUCERS ALLIANCE, SIERRA CLUB, TRASK FAMILY SEEDS, and WESTERN ORGANIZATION OF RESOURCE COUNCILS, Plaintiffs, v. THOMAS VILSACK, Secretary of Agriculture, and DR. GREGORY PARHAM, Administrator of the Animal and Plant Health Inspection Service, Defendants.
IGNACIA S. MORENO Assistant Attorney General Environment and Natural Resources Division PAUL D. BARKER, JR. CLIFFORD E. STEVENS, JR. Trial Attorneys, U.S. Department of Justice Environment & Natural Resources Division Natural Resources Section Wildlife & Marine Resources Section TONY WEST Assistant Attorney General JOHN R. GRIFFITHS Assistant Director, Federal Programs Branch BRYAN DEARINGER ERIC WOMACK Trial Attorneys, U.S. Department of Justice Civil Division, Federal Programs Branch Attorneys for Federal Defendants GEORGE A. KIMBRELL (Pro Hac Vice) PAIGE M. TOMASELLI State Bar No. 237737 KATERYNA L. RAKOWSKY State PAUL H. ACHITOFF (Pro Hac Vice) Attorneys for Plaintiffs
The Honorable
STIPULATED REQUEST FOR ORDER CHANGING TIME AND SUPPORTING JOINT DECLARATION
Pursuant to LR 6-2 and 7-12, the parties hereby file this stipulated request to slightly modify the summary judgment briefing schedule for this case. In support of this request, the parties hereby jointly declare the following:
1. Pursuant to a stipulated request for extension of the briefing schedule by the parties, on September 13, 2011, the Court ordered that the parties submit motions for summary judgment on September 22, 2011, oppositions on October 22, 2011, and reply briefs on November 9, 2011. Dkt. 100.
2. The current due date for oppositions, October 22, 2011, is a Saturday. The parties had not intended to request that opposition briefs be due over the weekend. Accordingly, the parties respectfully request that the Court extend the due date for opposition briefs to the following Monday, October 24, 2011.
3. The requested modification in the briefing schedule will not affect any other date for the case. The parties do not request any change to the November 9, 2011 due date for reply briefs. The schedule as modified by this stipulation will continue to provide for completion of briefing prior to the date for oral argument on December 2, 2011.
Respectfully submitted,
IGNACIA S. MORENO
Assistant Attorney General
Environment and Natural Resources Division
PAUL D. BARKER, JR.
CLIFFORD E. STEVENS, JR.
Trial Attorneys, U.S. Department of Justice
Environment & Natural Resources Division
Natural Resources Section
Wildlife & Marine Resources Section
TONY WEST
Assistant Attorney General
JOHN R. GRIFFITHS
Assistant Director, Federal Programs Branch
BRYAN DEARINGER
ERIC WOMACK
Trial Attorneys, U.S. Department of Justice
Civil Division, Federal Programs Branch
Attorneys for Federal Defendants
GEORGE A. KIMBRELL (Pro Hac Vice)
PAIGE M. TOMASELLI State Bar No. 237737
KATERYNA L. RAKOWSKY State
PAUL H. ACHITOFF (Pro Hac Vice)
Attorneys for Plaintiffs
PHILLIP JONATHAN PERRY
CLAUDIA M. O'BRIEN (Pro Hac Vice)
JANICE M. SCHNEIDER (Pro Hac Vice)
Latham & Watkins LLP
PATRICK JOHN FERGUSON
Latham & Watkins LLP
Attorneys for Defendant-Intervenor Monsanto Company
B. ANDREW BROWN (Pro Hac Vice)
Dorsey & Whitney LLP
MARTHA CORCORAN LUEMERS
Dorsey & Whitney LLP
Attorneys for Defendant-Intervenors Forage
Genetics International LLC, John Grover, Daniel
Mederos, Dan Scheps, Carl Simmons, Mark Watte,
California Alfalfa and Forage Association, Gardena
Alfalfa Seed Growers Association, Midwest Forage
Association, and Eureka Seeds, Inc.
CERTIFICATE OF SERVICE
I hereby certify that on this 12th day of October, 2011, I filed a copy of this document electronically through the CM/ECF system, which caused all parties or counsel to be served by electronic means as reflected on the Notice of Electronic Filing.
Clifford E. Stevens, Jr.
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
CENTER FOR FOOD SAFETY, BEYOND PESTICIDES, CORNUCOPIA INSTITUTE, CALIFORNIA FARMERS UNION, DAKOTA RESOURCES COUNCIL, GEERTSON SEED FARMS, NATIONAL FAMILY FARM COALITION, NORTHEAST ORGANIC DAIRY PRODUCERS ALLIANCE, SIERRA CLUB, TRASK FAMILY SEEDS, and WESTERN ORGANIZATION OF RESOURCE COUNCILS, Plaintiffs,
v.
THOMAS VILSACK, Secretary of Agriculture, and DR. GREGORY PARHAM, Administrator of the Animal and Plant Health Inspection Service, Defendants.
Case No.: 3:11-cv-01310-SC
The Honorable Samuel Conti
[PROPOSED] ORDER FOR STIPULATED REQUEST FOR ORDER CHANGING TIME AND SUPPORTING JOINT DECLARATION
PURSUANT TO STIPULATION, IT IS ORDERED that opposition briefs to the motions for summary judgment in the above-referenced case are due on October 24, 2011.