Deep Sea Fishermen's Union of the Pacific v. United States Department of Commerce

Opinion

District Judge John C. Coughenour

WESTERN DISTRICT OF WASHINGTON AT SEATTLE DEEP SEA FISHERMAN’S UNION OF Case No. C21-0452-JCC

STIPULATION FOR EXTENSION OF Plaintiff, TIME v. NOTED FOR CONSIDERATION:

UNITED STATES DEPARTMENT OF APRIL 28, 2021 COMMERCE, NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION, and NATIONAL MARINE FISHERIES SERVICE, Defendants.

COMES NOW, Plaintiff, Deep Sea Fisherman’s Union of the Pacific, and Defendants, United States Department of Commerce, National Oceanic and Atmospheric Administration, and National Marine Fisheries Service (collectively “Government”), by and through their counsel of record, pursuant to Federal Rule of Civil Procedure 6 and Local Rules 10(g) and 16, and hereby jointly stipulate and move for an extension of 30 days for Defendants to respond to the Complaint. Defendants’ responsive pleading to the Complaint is currently due May 10, 2021. A court may modify a deadline for good cause. Fed. R. Civ. P. 6(b). Continuing pretrial and trial dates is within the discretion of the trial judge. See King v. State of California, 784 F.2d 910, 912 (9th Cir. 1986). The parties submit there is good cause for an extension of the deadline. The parties are attempting to resolve Plaintiff’s claims short of further litigation. Counsel for the Government needs additional time to review materials and information in an effort to settle the matter. Continuing the existing deadline for a responsive pleading will allow the parties to conserve resources because they will not have to expend resources completing work when the case may become moot or may settle. Therefore, the parties stipulate and agree to a 30-day extension for Defendants to respond to the Complaint. If the matter is not resolved before then, Defendants will respond to the Complaint by June 10th, 2021. Stipulated to and presented this 28th day of April, 2021. TESSA M. GORMAN Acting United States Attorney s/ Spencer Nathan Thal s/ Nickolas Bohl Spencer Nathan Thal, WSBA No. 20074 Nickolas Bohl, WSBA No. 48978 Assistant United States Attorney United States Attorney’s Office s/ Zachariah Nathan William Thal 700 Stewart Street, Suite 5220 Zachariah Nathan William Thal, WSBA No. 55462 Seattle, Washington 98101-1271 Vanguard Law, LLC Phone: 206-553-7970 P.O. Box 939 Fax: 206-553-4067 Poulsbo, Washington 98370 Email: nickolas.bohl@usdoj.gov Phone: 206-488-8344 Email: spencer@vanguardlawfirm.com Attorneys for Defendants Email: zach@vanguardlawfirm.com

Attorneys for Plaintiff The parties having stipulated and agreed, it is hereby so ORDERED. DATED this 29th day of April, 2021. JOHN C. COUGHENOUR United States Judge

STIPULATION FOR EXTENSION OF TIME UNITED STATES ATTORNEY C?21-0452-JCC - 3 700 STEWART STREET. SUITE 5220