Leigh v. Raby ( 2024 )

1 TODD KIM, Assistant Attorney General S.JAY GOVINDAN, Section Chief 2 BRIDGET K. MCNEIL, Assistant Section Chief SAMANTHA G. PELTZ (IL Bar No. 6336536) 3 U.S. Department of Justice Environment and Natural Resources Division 4 Wildlife and Marine Resources Section, Natural Resources Section P.O. Box 7611 5 Washington, DC 20044 Tel: (202) 353-5959 (Peltz) 6 Fax: (202) 305-0275 Email: Samantha.Peltz@usdoj.gov 7 Attorneys for Federal Defendants 8 9 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 10 ANIMAL WELLNESS ACTION, a non- ) 11 profit corporation, CANA FOUNDATION, ) a non-profit corporation, THE CENTER FOR ) 12 A HUMANE ECONOMY, a non-profit ) Case No: 3:22-cv-00034-MMD-CLB corporation, LAURA LEIGH, individually, and ) 13 WILD HORSE EDUCATION, a non-profit ) corporation, ) 14 ) Plaintiffs, ) ORDER GRANTING JOINT 15 ) STIPULATION TO EXTEND THE v. ) 16 ) DEADLINE FOR FILING A UNITED STATES DEPARTMENT OF ) MOTION FOR ATTORNEYS’ FEES 17 INTERIOR, BUREAU OF LAND ) AND COSTS MANAGEMENT, and JON RABY, ) 18 Nevada State Director of the Bureau of Land ) Management, ) 19 ) Defendants. 20 ) 21 Pursuant to Local Rule IA 6-1, Plaintiffs Animal Wellness Action, Cana Foundation, 22 the Center for a Humane Economy, Laura Leigh, and Wild Horse Education, and Defendants 23 United States Department of Interior, Bureau of Land Management (“BLM”), and Jon Raby, 24 in his official capacity as Nevada State Director of the BLM, (collectively, the “Parties”), by 25 and through their undersigned counsel, hereby stipulate and respectfully request that the Court 26 extend the time to file any motions related to attorneys’ fees and costs 60 days, until August 27 12, 2024. In support of this request, the Parties declare: 1 WHEREAS, on March 28, 2024, the Court issued an opinion and order on the Parties’ 2 cross-motions for summary judgment. ECF No. 81. 3 WHEREAS, on March 29, 2024, judgment was entered by the Clerk of the Court. ECF 4 No. 82. 5 WHEREAS, on April 10, 2024, the parties filed a joint stipulation to extend the time 6 needed to explore the settlement of attorneys’ fees and costs. ECF No. 83. 7 WHEREAS, on April 11, 2024, the Court granted the parties’ joint stipulation. ECF 8 No. 84. 9 WHEREAS, the Parties remain interested in and are working cooperatively towards 10 settlement. Counsel for the Defendants has been delayed in responding to a settlement offer 11 by Plaintiffs due to unexpected litigation deadlines, including extensive travel, depositions, 12 and emergency motions. The Parties now agree that additional time is needed to explore the 13 settlement of attorneys’ fees and costs. 14 WHEREAS, this is the second stipulation for an extension of time to file a motion for 15 attorneys’ fees and costs. 16 WHEREAS, it is well-established that the court has the inherent power to “control the 17 disposition of the causes on its docket with economy of time and effort for itself, for counsel, 18 and for litigants.” Landis v. North Am. Co., 299 U.S. 248, 254 (1936); CMAX, Inc. v. Hall, 19 300 F.2d 265, 268 (9th Cir. 1962); Leyva v. Certified Grocers of California, 593 F.2d 857, 20 863-64 (9th Cir. 1979). 21 NOW, THEREFORE, IT IS STIPULATED BY AND BETWEEN THE PARTIES, 22 AND THE COURT ORDERS, AS FOLLOWS: 23 1. Upon entry of the Court’s order, the deadline to file any motion for attorneys’ fees 24 and costs is extended from June 11, 2024, until August 12, 2024. 25 IT IS SO STIPULATED. 26 Dated: June 6, 2024 Respectfully submitted, 27 TODD KIM 1 Assistant Attorney General U.S. Department of Justice 2 Environment & Natural Resources Division 3 S. JAY GOVINDAN, Section Chief BRIDGET K. MCNEIL, Assistant Section Chief 4 /s/_ Samantha G. Peltz 5 SAMANTHA G. PELTZ, Trial Attorney (IL Bar No. 6336536) 6 Natural Resources Section 7 Ben Franklin Station P.O. Box 7611 g Washington, D.C. 20044 Tel: (202) 353-5959 9 Samantha.peltz@usdoj.gov 10 Of Counsel: ll Janell M. Bogue U.S. Dep’t of the Interior 12 Office of the Solicitor Pacific Southwest Region 13 14 Attorneys for Federal Defendants 15 /s/ Danielle M. Holt Danielle M. Holt 16 (Nevada Bar No. 13152) DE CASTROVERDE LAW GROUP 17 1149 S Maryland Pkwy 18 Las Vegas, NV 89104 (702) 222-9999 19 danielle@decastroverdelaw.com 20 /s/ Jessica L. Blome 2] Jessica L. Blome (Cal. Bar No. 314898, admitted pro hac vice) 22 J. RAE LOVKO (Cal. Bar No. 208855, admitted pro hac vice) 23 GREENFIRE LAW, PC 24 2748 Adeline Street, Suite A Berkeley, CA 94703 25 (510) 900-9502 jblome@greenfirelaw.com 26 rlovko@greenfirelaw.com 27 $6 0 gouged?) 28 I, Hon. MIRANDA M. DU TINITEDN CTA TES NICTRICT TINE 1 CERTIFICATE OF SERVICE 2 I hereby certify that on June 6, 2024, I electronically filed the foregoing document with 3 the Clerk of the Court for the United States District Court for the District of Nevada using the 4 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/ Samantha G. Peltz k SAMANTHA G. PELTZ 9 Attorney for Defendant 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27