CONSENT MOT. TO ENLARGE 

TIME TO REPLY 1

JOHN C. CRUDEN

Assistant Attorney General

SEAN C. DUFFY (NY Bar. No. 4103131)

U.S. Department of Justice

Environment & Natural Resources Division

Natural Resources Section

601 D Street NW

Washington, DC 20004

Telephone: (202) 305-0445

Facsimile: (202) 305-0506

sean.c.duffy@usdoj.gov

Attorneys for Federal Defendants

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

EUGENE DIVISION

KELSEY CASCADIA ROSE JULIANA, et al.,

Plaintiffs,

v.

UNITED STATES OF AMERICA, et al.,

Federal Defendants.

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

FEDERAL DEFENDANTS’ 

CONSENT MOTION TO 

ENLARGE TIME TO 

REPLY

CONSENT MOTION TO ENLARGE TIME TO REPLY

Federal Defendants respectfully move the Court to enlarge their time to file a reply in 

support of their Motion to Dismiss (ECF No. 27). Under Fed. R. Civ. P. 6(b)(1), the Court may 

extend the time for filing the reply for good cause. The grounds for this motion are as follows:

1. Pursuant to the Court’s order (ECF No. 36) granting the Plaintiffs’ Consent Motion to 

Enlarge Time to Respond (ECF No. 35), Federal Defendants’ Reply in Support of 

their Motion to Dismiss is presently due by February 3, 2016. 

Case 6:15-cv-01517-TC Document 52 Filed 01/27/16 Page 1 of 3
CONSENT MOT. TO ENLARGE 

TIME TO REPLY 2

2. Plaintiffs’ response in opposition to Federal Defendants’ Motion to Dismiss is 

substantial, and includes a 45-page memorandum in support, as well as numerous 

supporting declarations and exhibits. See ECF Nos. 41, 43-47.

3. Plaintiffs named 22 individual and agency defendants in this case. Representatives 

for each defendant will need to review Federal Defendants’ reply in support of the 

Motion to Dismiss and provide necessary feedback. 

4. Due to a recent snow-storm, federal offices in Washington, DC closed at noon last 

Friday (January 22) and did not reopen until today (January 27) after a three-hour 

delay in the morning. This closure has delayed the preparation of the reply.

5. Undersigned counsel approached Plaintiffs and Intervenor-Defendants today 

regarding an extension of time to file a reply.

6. Plaintiffs and Intervenor-Defendants have consented to permit Federal Defendants to 

file the reply in support of the Motion to Dismiss by February 10, 2016.

7. Granting this motion will serve the public interest by ensuring that counsel for

Federal Defendants has sufficient time to provide a well-researched, well-drafted, and 

well-edited reply brief, with necessary feedback from representatives of the 

individual and agency defendants. On the other hand, denying the motion would 

cause undue prejudice and harm to Federal Defendants’ positions because their 

counsel would not have adequate time to complete the research and drafting process, 

submit the reply for review by representatives of the individual and agency 

defendants, and incorporate feedback before filing the reply.

Accordingly, Federal Defendants respectfully request an enlargement of one week to file 

a reply in support of the Motion to Dismiss, so that it is due by February 10, 2016.

Case 6:15-cv-01517-TC Document 52 Filed 01/27/16 Page 2 of 3
CONSENT MOT. TO ENLARGE 

TIME TO REPLY 3

Dated: January 27, 2016 Respectfully submitted,

JOHN C. CRUDEN

Assistant Attorney General

Environment & Natural Resources Division

s/ Sean C. Duffy 

SEAN C. DUFFY (NY Bar. No. 4103131)

U.S. Department of Justice

Environment & Natural Resources Division

Natural Resources Section

601 D Street NW

Washington, DC 20004

Telephone: (202) 305-0445

Facsimile: (202) 305-0506

sean.c.duffy@usdoj.gov

Attorneys for Federal Defendants

Certificate of Service

I hereby certify that on January 27, 2016, I filed the foregoing with the Clerk of Court via 

the CM/ECF system, which will provide service to all attorneys of record.

s/ Sean C. Duffy

Sean C. Duffy

Attorney for Federal Defendants

Case 6:15-cv-01517-TC Document 52 Filed 01/27/16 Page 3 of 3