Plaintiffs’ Consent Motion to Enlarge Page Limit; 6:15-cv-01517-TC

JULIA A. OLSON (OR Bar 062230) 

JuliaAOlson@gmail.com

WILD EARTH ADVOCATES

1216 Lincoln Street

Eugene, OR 97401

Tel: (415) 786-4825 

JOSEPH W. COTCHETT 

jcotchett@cpmlegal.com

PHILIP L. GREGORY (pro hac vice) 

pgregory@cpmlegal.com

PAUL N. MCCLOSKEY 

pmccloskey@cpmlegal.com

COTCHETT, PITRE & McCARTHY, LLP

San Francisco Airport Office Center

840 Malcolm Road

Burlingame, CA 94010

Tel: (650) 697-6000

Fax: (650) 697-0577

DANIEL M. GALPERN (OR Bar 061950)

dan.galpern@gmail.com

LAW OFFICES OF DANIEL M. GALPERN

1641 Oak Street

Eugene, OR 97401

Tel: (541) 968-7164

Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

EUGENE DIVISION

KELSEY CASCADIA ROSE JULIANA;

XIUHTEZCATL TONATIUH M., through 

his Guardian Tamara Roske-Martinez; et al.

Plaintiffs,

v.

Case No.: 6:15-cv-01517-TC 

PLAINTIFFS’ CONSENT MOTION TO 

ENLARGE PAGE LIMIT 
Plaintiffs’ Consent Motion to Enlarge Page Limit; 6:15-cv-01517-TC

The UNITED STATES OF AMERICA; 

BARACK OBAMA, in his official capacity as 

President of the United States; et al., 

Federal Defendants.

CONSENT MOTION TO ENLARGE PAGE LIMIT

Plaintiffs respectfully move this Court to enlarge their page limit for their memorandum 

to oppose Federal Defendants’ Motion to Dismiss under Local Rule 7-2(b)(1), which is due on 

January 6, 2016, from 35 pages to 45 pages, with no word limitation. Under Local Rule 7-

2(b)(1), the Court may for good cause enlarge the page limit time for a memorandum. The 

grounds for this Motion are as follows:

1. The Amended Complaint in this matter was filed on September 10, 2015. On 

September 28, 2015, Federal Defendants filed a consent motion to enlarge the time to 

file an Answer or responsive pleading. The Court granted the Motion.

2. On November 13, 2015, Federal Defendants filed a second consent motion to enlarge 

the time to file an Answer or responsive pleading. The Court granted the motion. 

3. On November 17, 2015, Federal Defendants filed a Motion to Dismiss pursuant Rule 

12(b), subsections (1) and (6), of the Federal Rules of Civil Procedure. The Motion 

to Dismiss raises important issues regarding standing, constitutional rights, and the 

public trust doctrine, and requires a thorough argument on each of Plaintiffs’ causes 

of action.

4. Plaintiffs have worked diligently to limit the pages in their brief and still provide the 

court with a complete argument on the Motion, to be filed tomorrow, January 6, 2015.
Plaintiffs’ Consent Motion to Enlarge Page Limit; 6:15-cv-01517-TC

5. Local Rule 7-2(b)(1) provides: “Without prior Court approval, memoranda (including 

objections to a Findings and Recommendation of a Magistrate Judge and responses to 

such objections) may not exceed 11,000 words, or in the alternative, 35 pages. If the 

document exceeds the page limit, then the party must certify compliance with the 

word-count limit. This limitation includes headings, footnotes and quotations, but 

excludes the caption, table of contents, table of cases and authorities, signature block, 

exhibits, and any certificates of counsel.”

6. Plaintiffs requested and Federal Defendants consented to extending the page limit of 

Plaintiffs’ memorandum to oppose the Motion to Dismiss to 45 pages, with no word 

limitation. Neither party has previously requested to extend the page limit.

7. Neither party has been guilty of negligence or bad faith.

Accordingly, Plaintiffs hereby respectfully request enlarge their page limit for their 

memorandum to oppose Federal Defendants’ Motion to Dismiss under Local Rule 7-2(b)(1) 

from 35 pages to 45 pages, with no word limitation. A proposed Order is attached.

Respectfully submitted this 5th day of January, 2016.

s/ Julia A. Olson 

JULIA A. OLSON (OR Bar 062230) 

JuliaAOlson@gmail.com 

1216 Lincoln St. 

Eugene, OR 97401 

Tel: (415) 786-4825 

PHILIP L. GREGORY (applicant pro hac vice) 

pgregory@cpmlegal.com

840 Malcolm Road 

Burlingame, CA 94010 

Tel: (650) 697-6000 

DANIEL M. GALPERN (OR Bar 061950) 

dan.galpern@gmail.com

1641 Oak Street 
Plaintiffs’ Consent Motion to Enlarge Page Limit; 6:15-cv-01517-TC

Eugene, OR 97401 Tel: (541) 968-7164 

Attorneys for Plaintiffs 
Plaintiffs’ Consent Motion to Enlarge Page Limit; 6:15-cv-01517-TC

CERTIFICATE OF SERVICE

I hereby certify that on this 5th day of January, 2016, a copy of the foregoing Consent 

Motion to Enlarge Page Limit was filed via the Court’s electronic case filing (ECF) system, 

which will send notice to all counsel of record.

/s/ Julia A. Olson

JULIA A. OLSON