Leigh v. Raby ( 2024 )

1 TODD KIM, Assistant Attorney General S.JAY GOVINDAN, Section Chief 2 BRIDGET K. MCNEIL, Assistant Section Chief CHRISTIAN H. CARRARA (NJ Bar No. 317732020) 3 SAMANTHA G. PELTZ (IL Bar No. 6336536) U.S. Department of Justice 4 Environment and Natural Resources Division Wildlife and Marine Resources Section, Natural Resources Section 5 P.O. Box 7611 Washington, DC 20044 6 Tel: (202) 598-9736 (Carrara) Fax: (202) 305-0275 7 Email: Christian.Carrara@usdoj.gov 8 Attorneys for Federal Defendants 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 ANIMAL WELLNESS ACTION, a non- ) profit corporation, CANA FOUNDATION, ) 12 a non-profit corporation, THE CENTER FOR ) A HUMANE ECONOMY, a non-profit ) Case No: 3:22-cv-00034-MMD-CLB 13 corporation, LAURA LEIGH, individually, and ) WILD HORSE EDUCATION, a non-profit ) 14 corporation, ) ) 15 Plaintiffs, ) ORDER GRANTING FOURTH ) JOINT STIPULATION TO EXTEND 16 v. ) THE DEADLINE FOR FILING A ) 17 UNITED STATES DEPARTMENT OF ) MOTION FOR ATTORNEYS’ FEES INTERIOR, BUREAU OF LAND ) 18 MANAGEMENT, and JON RABY, ) Nevada State Director of the Bureau of Land ) 19 Management, ) ) 20 Defendants. ) 21 22 Pursuant to Local Rule IA 6-1, Plaintiffs Animal Wellness Action, Cana Foundation, 23 The Center for a Humane Economy, Laura Leigh, and Wild Horse Education, and Defendants 24 United States Department of Interior, Bureau of Land Management (“BLM”), and Jon Raby, 25 in his official capacity as Nevada State Director of the BLM (collectively, the “Parties”), by and through their undersigned counsel, hereby stipulate and respectfully request that the Court 26 27 1 extend the time to file any motions related to attorneys’ fees and costs 32 days, until 2 November 12, 2024. The Parties declare in support of this request: 3 WHEREAS, on March 28, 2024, the Court issued an opinion and order on the Parties’ 4 cross-motions for summary judgment. ECF No. 81. 5 WHEREAS, on March 29, 2024, judgment was entered by the Clerk of the Court. ECF 6 No. 82. 7 WHEREAS, on April 10, 2024, the Parties filed a joint stipulation to extend the time 8 needed to explore the settlement of attorneys’ fees and costs. ECF No. 83. 9 WHEREAS, on April 11, 2024, the Court granted the Parties’ joint stipulation. ECF 10 No. 84. 11 WHEREAS, on June 6, 2024, the Parties filed a second joint stipulation to extend the 12 time needed to explore the settlement of attorneys’ fees and costs. ECF No. 87. 13 WHERAS, on June 6, 2024, the Court granted the Parties’ second joint stipulation. 14 ECF No. 88. 15 WHEREAS, on August 1, 2024, the Parties filed a third joint stipulation to extend the 16 time needed to explore the settlement of attorneys’ fees and costs. ECF No. 93. 17 WHEREAS, on August 1, 2024, the Court granted the Parties’ third joint stipulation 18 and extended the deadline for Plaintiffs to file a motion for attorneys’ fees until October 11, 19 2024. ECF No. 94. 20 WHEREAS, the Parties have reached an agreement in principle, and agree that an 21 additional 32 days is necessary to finalize and obtain approval for any settlement agreement. 22 WHEREAS, it is well-established that the court has the inherent power to “control the 23 disposition of the causes on its docket with economy of time and effort for itself, for counsel, 24 and for litigants.” Landis v. North Am. Co., 299 U.S. 248, 254 (1936); CMAX, Inc. v. Hall, 25 300 F.2d 265, 268 (9th Cir. 1962); Leyva v. Certified Grocers of California, 593 F.2d 857, 26 863-64 (9th Cir. 1979). 27 1 NOW, THEREFORE, IT IS STIPULATED BY AND BETWEEN THE PARTIES, 2 AND THE COURT ORDERS, AS FOLLOWS: 3 1. Upon entry of the Court’s order, the deadline to file any motion for attorneys’ fees 4 and costs is extended from October 11, 2024, until November 12, 2024. 5 IT IS SO STIPULATED. 6 Dated: October 8, 2024 Respectfully submitted, 7 TODD KIM 8 Assistant Attorney General U.S. Department of Justice 9 Environment & Natural Resources Division S.JAY GOVINDAN, Section Chief 10 BRIDGET K. MCNEIL, Assistant Section Chief 11 /s/ Christian H. Carrara 12 CHRISTIAN H. CARRARA, Trial Attorney (NJ Bar No. 317732020) 13 Wildlife and Marine Resources Section SAMANTHA PELTZ, Trial Attorney 14 (IL Bar No. 6336536) 15 Natural Resources Section Ben Franklin Station 16 P.O. Box 7611 Washington, D.C. 20044 17 Tel: (202) 598-9736 (Carrara) Fax: 202-305-0275 18 Christian.carrara@usdoj.gov 19 Of Counsel: 20 Janell M. Bogue U.S. Dep’t of the Interior 21 Office of the Solicitor Pacific Southwest Region 22 23 Attorneys for Federal Defendants 24 /s/ Jessica L. Blome 25 Jessica L. Blome (Cal. Bar No. 314898, admitted pro hac vice) 26 J.RAE LOVKO 27 (Cal. Bar No. 208855, admitted pro hac vice) 1 GREENFIRE LAW, PC 2748 Adeline Street, Suite A 2 Berkeley, CA 94703 3 (510) 900-9502 jblome@ greenfirelaw.com 4 rlovko@ greenfirelaw.com 5 Attorneys for Plaintiffs 6 7 IT IS $00 ebipEDY 8 “iid 9 MIRANDA M. DU 10 UNITED STATES DISTRICT JUDGE i DATED: _October 2024 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 CERTIFICATE OF SERVICE 2 I hereby certify that on October 8, 2024, I electronically filed the foregoing document 3 with the Clerk of the Court for the United States District Court for the District of Nevada using 4 the Court’s CM/ECF system. Participants in the case who are registered CM/ECF users will be 5 served by the appellate CM/ECF system, which includes counsel of record for all parties in the 6 case. 7 8 /s/ Christian H. Carrara CHRISTIAN H. CARRARA 9 Attorney for Federal Defendants 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27