1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`Case 4:20-cv-00256-JSW Document 41 Filed 02/17/21 Page 1 of 3
`
`SYLVIA SHIH-YAU WU (CA Bar No. 273549)
`Center for Food Safety
`303 Sacramento Street, 2nd floor
`San Francisco, CA 94111
`(p) 415-826-2770 / (f) 415-826-0507
`swu@centerforfoodsafety.org
`
`RYAN D. TALBOTT
`Pro Hac Vice
`AMY VAN SAUN
`Pro Hac Vice
`Center for Food Safety
`2009 NE Alberta Street, Suite 207
`Portland, OR 97211
`(p) 971-271-7372
`rtalbott@centerforfoodsafety.org
`avansaun@centerforfoodsafety.org
`
`ZACHARY B. CORRIGAN
`Pro Hac Vice
`Food & Water Watch, Inc.
`1616 P Street, NW, Suite 300
`Washington, DC 20036
`(p) 202-683-2451 / (f) 202-683-2452
`zcorrigan@fwwatch.org
`
`JAMES B. DOUGHERTY
`Pro Hac Vice
`700 7th St. SW, Suite 805
`Washington, DC 20024
`(p) 202-488-1140
`jimdougherty@aol.com
`
`Counsel for Plaintiffs
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`OAKLAND DIVISION
`
`
`
`
`Case No. 4:20-cv-00256-JSW
`
`
`CENTER FOR FOOD SAFETY, et al.,
`Plaintiffs,
`
`
`v.
`
`
`SONNY PERDUE, in his official capacity
`as the Secretary of the U.S. Department of
`Agriculture, et al.;
`
`
`
`
`Defendants.
`
`STIPULATION AND PROPOSED ORDER GRANTING
`PLAINTIFFS LEAVE TO FILE A SECOND AMENDED
`COMPLAINT AND DEFENDANTS AN EXTENSION
`OF TIME TO ANSWER PLAINTIFFS’ COMPLAINT
`
`Judge: Honorable Jeffrey S. White
`
`No hearing date is scheduled or requested
`Center for Food Safety et al. v. Perdue et al., 4:20-cv-00256-JSW
`Stipulation and Proposed Order Granting Pls. Leave to File Second Am. Compl. and Defs. an Extension of Time to Answer Pls.’
`Compl.
`
`
`
`
`
`1
`
`
`
`
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`Case 4:20-cv-00256-JSW Document 41 Filed 02/17/21 Page 1 of 3
`
`SYLVIA SHIH-YAU WU (CA Bar No. 273549)
`Center for Food Safety
`303 Sacramento Street, 2nd floor
`San Francisco, CA 94111
`(p) 415-826-2770 / (f) 415-826-0507
`swu@centerforfoodsafety.org
`
`RYAN D. TALBOTT
`Pro Hac Vice
`AMY VAN SAUN
`Pro Hac Vice
`Center for Food Safety
`2009 NE Alberta Street, Suite 207
`Portland, OR 97211
`(p) 971-271-7372
`rtalbott@centerforfoodsafety.org
`avansaun@centerforfoodsafety.org
`
`ZACHARY B. CORRIGAN
`Pro Hac Vice
`Food & Water Watch, Inc.
`1616 P Street, NW, Suite 300
`Washington, DC 20036
`(p) 202-683-2451 / (f) 202-683-2452
`zcorrigan@fwwatch.org
`
`JAMES B. DOUGHERTY
`Pro Hac Vice
`700 7th St. SW, Suite 805
`Washington, DC 20024
`(p) 202-488-1140
`jimdougherty@aol.com
`
`Counsel for Plaintiffs
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`OAKLAND DIVISION
`
`
`
`
`Case No. 4:20-cv-00256-JSW
`
`
`CENTER FOR FOOD SAFETY, et al.,
`Plaintiffs,
`
`
`v.
`
`
`SONNY PERDUE, in his official capacity
`as the Secretary of the U.S. Department of
`Agriculture, et al.;
`
`
`
`
`Defendants.
`
`STIPULATION AND PROPOSED ORDER GRANTING
`PLAINTIFFS LEAVE TO FILE A SECOND AMENDED
`COMPLAINT AND DEFENDANTS AN EXTENSION
`OF TIME TO ANSWER PLAINTIFFS’ COMPLAINT
`
`Judge: Honorable Jeffrey S. White
`
`No hearing date is scheduled or requested
`Center for Food Safety et al. v. Perdue et al., 4:20-cv-00256-JSW
`Stipulation and Proposed Order Granting Pls. Leave to File Second Am. Compl. and Defs. an Extension of Time to Answer Pls.’
`Compl.
`
`
`
`
`
`1
`
`
`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`Case 4:20-cv-00256-JSW Document 41 Filed 02/17/21 Page 2 of 3
`
`
`
`
`
`STIPULATION AND PROPOSED ORDER
`Plaintiffs Center for Food Safety, Food & Water Watch, Inc., Humane Farming Association, and Robin
`Mangini, and Defendants Sonny Perdue,* in his official capacity as Secretary of the U.S. Department of
`Agriculture; Mindy Brashears,* in her official capacity as Deputy Undersecretary for Food Safety, U.S.
`Department of Agriculture; Food Safety and Inspection Service; and U.S. Department of Agriculture, through
`their respective undersigned counsel, make the following stipulated requests:
`1.
` The counsel for parties hereby stipulate to Plaintiffs filing a Second Amended Complaint on
`February 18, 2021. The complaint makes minor technical changes and adds material that was obtained and
`learned by the Plaintiff after the filing of their Second Amended complaint. Fed. R. Civ. P. 15(a)(2) allows a
`party to amend its pleading with the opposing party’s written consent.
`2.
`Pursuant to Local Rule 6.1(a), counsel for parties further stipulate to extending the time for
`Defendants to answer the complaint until March 18, 2021. The change will not alter the date of any event or
`any deadline already fixed by court order.
`
`Dated: February 17, 2021
`
`
`
`Respectfully submitted,
`
`
`
`* Secretary Perdue and Under Secretary Brashears no longer hold office, so their successors are to be
`automatically substituted as parties under to Fed. R. Civ. P. 15(d). As of this filing, successors have
`yet to take office.
`Center for Food Safety et al. v. Perdue et al., 4:20-cv-00256-JSW
`Stipulation and Proposed Order Granting Pls. Leave to File Second Am. Compl. and Defs. an Extension of Time to Answer Pls.’
`Compl.
`
`
`
`
`
`2
`
`
`
`
`
`Case 4:20-cv-00256-JSW Document 41 Filed 02/17/21 Page 3 of 3
`
`
`
`BRIAN BOYNTON
`Acting Assistant Attorney General
`
`ERIC R. WOMACK
`Assistant Branch Director
`Federal Programs Branch
`
`
` /s/ Joseph J. DeMott
`JOSEPH J. DEMOTT (Va. Bar No. 93981)
`Trial Attorney
`United States Department of Justice
`Civil Division, Federal Programs Branch
`1100 L St. NW
`Washington, DC 20530
`Phone: (202) 514-3367
`Fax: (202) 616-8470
`Email: joseph.demott@usdoj.gov
`
`Counsel for Defendants
`
`
` SYLVIA SHIH-YAU WU (CA Bar No. 273549)
`Center for Food Safety
`303 Sacramento Street, 2nd floor
`San Francisco, CA 94111
`(p) 415-826-2770 / (f) 415-826-0507
`swu@centerforfoodsafety.org
`
`RYAN D. TALBOTT (Pro Hac Vice)
`AMY VAN SAUN (Pro Hac Vice)
`Center for Food Safety
`2009 NE Alberta Street, Suite 207
`Portland, OR 97211
`(p) 971-271-7372
`rtalbott@centerforfoodsafety.org
`avansaun@centerforfoodsafety.org
`
`/s/ Zachary B. Corrigan
`
`ZACHARY B. CORRIGAN (D.C. Bar No.
`497557)
` (Pro Hac Vice)
` Food & Water Watch
` 1616 P Street NW, Suite 300
` Washington, DC 20036
` (p) (202) 683-2451 / (f) (202) 683-2452
` zcorrigan@fwwatch.org
`
`
` Counsel for Plaintiffs
`
`
`
`
`PURSUANT TO STIPULATION, IT IS SO ORDERED
`
`
`
`
`Dated: __________________
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`_________________________
`JEFFREY S. WHITE
`United States District Judge
`
`Center for Food Safety et al. v. Perdue et al., 4:20-cv-00256-JSW
`Stipulation and Proposed Order Granting Pls. Leave to File Second Am. Compl. and Defs. an Extension of Time to Answer Pls.’
`Compl.
`
`
`
`
`
`
`3
`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`February 17, 2021
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
