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Stipulation of the Parties to Continue Hearing Date; [Proposed] Order

Case No .Civ-04-1027 WBS/GGH 1

Sharon E. Duggan, CSB # 105108

Law Offices of Sharon E. Duggan

370 Grand Avenue, Suite 5

Oakland, CA 94610

(510) 271-0825 telephone

(510) 271-0829 facsimile

Internet e-mail address foxsduggan@aol.com

Erin Madden, OSB # 04468

Attorney at Law

917 SW Oak Street Suite 914

Portland, Oregon 97205

(503) 796-7811 telephone

(503) 296-2973 facsimile

Internet e-mail address erin@kswild.org

Attorneys for Plaintiffs

McGREGOR W. SCOTT

United States Attorney

EDMUND F. BRENNAN

E. ROBERT WRIGHT

Assistant United States Attorney

501 I Street Suite 10-100

Sacramento, CA 95814

(916) 554-2702

Internet e-mail address e.robert.wright@usdoj.gov

Attorneys for Defendants

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF CALIFORNIA

ENVIRONMENTAL PROTECTION 

AND INFORMATION CENTER, a

California nonprofit corporation; and

KLAMATH-SISKIYOU WILDLANDS

CENTER, an Oregon nonprofit 

corporation,

Plaintiffs, 

v.

Jack BLACKWELL, in his official capacity

as Regional Forester for the Southwest

Pacific Region of the United States Forest

Service; Margaret BOLAND, in her official

capacity as Forest Supervisor for the

Klamath National Forest; and UNITED

STATES FOREST SERVICE, 

Defendants.

Civil No. Civ-04-1027 WBSGGH

CORRECTED

STIPULATION OF THE PARTIES TO

CONTINUE THE HEARING DATE FOR

THE PLAINTIFFS’ MOTION FOR

ATTORNEYS’ FEES AND COSTS;

[PROPOSED] ORDER

Case 2:04-cv-01027-WBS-GGH Document 57 Filed 11/23/05 Page 1 of 3
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Stipulation of the Parties to Continue Hearing Date; [Proposed] Order

Case No .Civ-04-1027 WBS/GGH 2

The Plaintiffs Environmental Protection Information Center and the Klamath-Siskiyou

Wildlands Center, and Defendants Jack Blackwell, in his official capacity as Regional Forester

for the Southwest Pacific Region of the United States Forest Service, Margaret Boland, in her

official capacity as Forest Supervisors for the Klamath National Forest, and the United States

Forest Service, by and through their respective counsel stipulate as follows:

WHEREAS the Plaintiffs’ have filed a Motion for Attorneys’ Fees and Costs, which is

set for hearing on December 12, 2005 at 1:30 p.m.;

WHEREAS the parties wish to extend the motion hearing date as they are in the

settlement discussions to resolve the motion and believe it is appropriate to allow additional time

to complete settlement discussions; and

WHEREAS, the parties respectfully request that the Court extend the motion hearing date

to allow the parties to complete settlement discussions;

THEREFORE THE PARTIES, THROUGH THEIR RESPECTIVE COUNSEL,

STIPULATE AS FOLLOWS:

The parties agree to and request that the Court continue the December 12, 2005 hearing

date for the Plaintiffs’ Motion for Attorneys’ Fees and Costs to January 23, 2006 at 1:30 p.m.

DATED: November 22, 2005 /s/ Sharon E. Duggan 

Sharon E. Duggan

Attorney for Plaintiffs

DATED: November 22, 2005 /s/ E. Robert Wright 

E. ROBERT WRIGHT

Assistant U. S. Attorney

Attorneys for Defendants

Case 2:04-cv-01027-WBS-GGH Document 57 Filed 11/23/05 Page 2 of 3
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Stipulation of the Parties to Continue Hearing Date; [Proposed] Order

Case No .Civ-04-1027 WBS/GGH 3

ORDER

The parties having so stipulated, the hearing date on the Plaintiffs’ Motion for Attorneys’

Fees and Costs, currently set for December 12, 2005 at 1:30 p.m., is continued to January 23,

2006 at 1:30 p.m.

DATED: November 22, 2005

Case 2:04-cv-01027-WBS-GGH Document 57 Filed 11/23/05 Page 3 of 3