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

Opinion

1 District Judge John C. Coughenour

8 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 9 AT SEATTLE 10 DEEP SEA FISHERMAN’S UNION OF Case No. C21-0452-JCC

11 THE PACIFIC, STIPULATION FOR EXTENSION OF 12 Plaintiff, TIME 13 v. NOTED FOR CONSIDERATION:

14 UNITED STATES DEPARTMENT OF APRIL 28, 2021 COMMERCE, NATIONAL OCEANIC 15 AND ATMOSPHERIC 16 ADMINISTRATION, and NATIONAL MARINE FISHERIES SERVICE, 17 Defendants. 18

19 20 COMES NOW, Plaintiff, Deep Sea Fisherman’s Union of the Pacific, and Defendants, 21 United States Department of Commerce, National Oceanic and Atmospheric Administration, and 22 National Marine Fisheries Service (collectively “Government”), by and through their counsel of 23 record, pursuant to Federal Rule of Civil Procedure 6 and Local Rules 10(g) and 16, and hereby 24 jointly stipulate and move for an extension of 30 days for Defendants to respond to the Complaint. 25 Defendants’ responsive pleading to the Complaint is currently due May 10, 2021. 26 27 28 1 A court may modify a deadline for good cause. Fed. R. Civ. P. 6(b). Continuing pretrial 2 and trial dates is within the discretion of the trial judge. See King v. State of California, 3 784 F.2d 910, 912 (9th Cir. 1986). 4 The parties submit there is good cause for an extension of the deadline. The parties are 5 attempting to resolve Plaintiff’s claims short of further litigation. Counsel for the Government 6 needs additional time to review materials and information in an effort to settle the matter. 7 Continuing the existing deadline for a responsive pleading will allow the parties to conserve 8 resources because they will not have to expend resources completing work when the case may 9 become moot or may settle. 10 Therefore, the parties stipulate and agree to a 30-day extension for Defendants to respond to 11 the Complaint. If the matter is not resolved before then, Defendants will respond to the Complaint 12 by June 10th, 2021. 13 Stipulated to and presented this 28th day of April, 2021. 14 TESSA M. GORMAN 15 Acting United States Attorney 16 s/ Spencer Nathan Thal s/ Nickolas Bohl 17 Spencer Nathan Thal, WSBA No. 20074 Nickolas Bohl, WSBA No. 48978 Assistant United States Attorney 18 United States Attorney’s Office s/ Zachariah Nathan William Thal 700 Stewart Street, Suite 5220 19 Zachariah Nathan William Thal, WSBA No. 55462 Seattle, Washington 98101-1271 20 Vanguard Law, LLC Phone: 206-553-7970 P.O. Box 939 Fax: 206-553-4067 21 Poulsbo, Washington 98370 Email: nickolas.bohl@usdoj.gov Phone: 206-488-8344 22 Email: spencer@vanguardlawfirm.com Attorneys for Defendants Email: zach@vanguardlawfirm.com 23

24 Attorneys for Plaintiff 25 26 27 28 1 ORDER 2 The parties having stipulated and agreed, it is hereby so ORDERED. 3 4 DATED this 29th day of April, 2021. 5 9 JOHN C. COUGHENOUR 10 United States Judge 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

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