Leigh v. Raby

1 TODD KIM, Assistant Attorney General S.JAY GOVINDAN, Section Chief BRIDGET K. MCNEIL, Assistant Section Chief SAMANTHA G. PELTZ (IL Bar No. 6336536) U.S. Department of Justice Environment and Natural Resources Division Wildlife and Marine Resources Section, Natural Resources Section P.O. Box 7611 Washington, DC 20044 Tel: (202) 353-5959 (Peltz) Fax: (202) 305-0275 Email: [email protected] Attorneys for Federal Defendants 9 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 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, ) ) Defendants.

20 ) Pursuant to Local Rule IA 6-1, Plaintiffs Animal Wellness Action, Cana Foundation, the Center for a Humane Economy, Laura Leigh, and Wild Horse Education, and Defendants United States Department of Interior, Bureau of Land Management (“BLM”), and Jon Raby, 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 extend the time to file any motions related to attorneys’ fees and costs 60 days, until June 11, 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’ cross-motions for summary judgment. ECF No. 81.

3 WHEREAS, on March 29, 2024, judgment was entered by the Clerk of the Court. ECF No. 82.

5 WHEREAS, the deadline to file a motion for attorneys’ fees and costs under Fed. R. Civ. P. 54(d)(2)(B)(i) is April 12, 2024.

7 WHEREAS, the Parties agree that additional time is needed to explore the settlement of attorneys’ fees and costs.

9 WHEREAS, this is the first stipulation for an extension of time to file a motion for attorneys’ fees and costs.

11 WHEREAS, it is well-established that the court has the inherent power to “control the disposition of the causes on its docket with economy of time and effort for itself, for counsel, and for litigants.” Landis v. North Am. Co., 299 U.S. 248, 254 (1936); CMAX, Inc. v. Hall, 300 F.2d 265, 268 (9th Cir. 1962); Leyva v. Certified Grocers of California, 593 F.2d 857, 863-64 (9th Cir. 1979).

16 NOW, THEREFORE, IT IS STIPULATED BY AND BETWEEN THE PARTIES, AND THE COURT ORDERS, AS FOLLOWS: 18 1. Upon entry of the Court’s order, the deadline to file any motion for attorneys’ fees 19 and costs is extended from April 12, 2024, until June 11, 2024.

20 IT IS SO STIPULATED.

21 Dated: April 10, 2024 Respectfully submitted, TODD KIM 23 Assistant Attorney General U.S. Department of Justice 24 Environment & Natural Resources Division S.JAY GOVINDAN, Section Chief 25 BRIDGET K. MCNEIL, Assistant Section Chief /s/ Samantha G. Peltz j 27 SAMANTHA G. PELTZ, Trial Attorney 1 (IL Bar No. 6336536) Natural Resources Section 2 Ben Franklin Station P.O. Box 7611 Washington, D.C. 20044 4 Tel: (202) 353-5959 [email protected] Of Counsel: 6 Janell M. Bogue U.S. Dep’t of the Interior Office of the Solicitor 8 Pacific Southwest Region 9 Attorneys for Federal Defendants 10 /s/ Danielle M. Holt Danielle M. Holt (Nevada Bar No. 13152) 12 DE CASTROVERDE LAW GROUP 1149 S Maryland Pkwy 13 Las Vegas, NV 89104 (702) 222-9999 [email protected] /s/ Jessica L. Blome Jessica L. Blome 17 (Cal. Bar No. 314898, admitted pro hac vice) J. RAE LOVKO 18 (Cal. Bar No. 208855, admitted pro hac vice) GREENFIRE LAW, PC 19 2748 Adeline Street, Suite A Berkeley, CA 94703 (510) 900-9502 21 [email protected] [email protected] 23 Attorneys for Plaintiffs

1 IT IS SO ORDERED: 2 ASR Hon. MIRANDA M. DU 3 UNITED STATES DISTRICT JUDGE 4 DATED: 4/11/2024