IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
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UNITED STATES OF AMERICA, et Plaintiffs, v. SOUTH FLORIDA WATER
Defendants.
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CASE NO: 88-1886-CIV-HOEVELER
MICCOSUKEE TRIBE'S MOTION |
The undersigned attorney, as counsel for the Miccosukee Tribe of Indians of Florida (the Tribe"), requests an eleven-day extension of time through July 9, 1996 in which to file its response to Defendant-Intervenors', Western Palm Beach County Farm Bureau, Inc., Roth Farms, Inc. and K.W.B. Farms' ("collectively farmer-intervenors") Motion to Strike and Memorandum in Opposition to Tribe's Supplemental Emergency Motion to Enforce and states as grounds as follows:
1 . The Tribe's response is presently due on June 28, 1996.
2. The press of business and the fact that the farmer-intervenors' Motion to Strike and Memorandum in Opposition to Tribe's Supplemental Emergency Motion to Enforce addresses issues outside the scope of the Tribe's Supplemental Emergency Motion to Enforce and this litigation necessitate an eleven-day extension of time to respond to the farmer intervenors' Motion to Strike and Memorandum in Opposition to Tribe's Supplemental Emegency Motion to Enforce.
3. Undersigned counsel telephoned counsel for the farmer-intervenors, William
Green, Esq., on June 21, 1996, who did not object to the Tribe's request for additional time to file its response.For the foregoing reasons, the Tribe respectfully requests that this Court grant this motion for extension of time and grant the Tribe an extension of time through July 9, 1996 in which to file its response to the farmer-intervenors' Motion to Strike and Memorandum in Opposition to Tribe's Supplemental Emergency Motion to Enforce. A proposed order granting the present motion is attached hereto as Exhibit "A".
Respectfully submitted,
LEHTINEN, O'DONNELL, VARGAS
& REINER, P.A.
Attorneys for Plaintiffs
7700 N. Kendall Drive, Suite 303
Miami, FL 33156
Telephone: (305) 279-1166
Facsimile: (305) 279-1365By:___________________
Maria J. Santovenia, Esq.
Florida Bar No. 801445
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served by mail on June 28, 1996 upon all of the addressees listed below.
________________________
Maria J. Santovenia, Esq.
Addressees:
Ms. Lisa Hogan
Kenneth F. Hoffman, Esq.
Assistant United States Attorney
Oertel, Hoffman, Fernandez
99 Northeast 4th Street
& Cole, P.A.
3rd Floor
2700 Blair Stone Road
Miami, FL 33132
Tallahassee, FL 32301
Ms. Barbara Markham
Jeffrey J. Ward, Esq.
General Counsel
P.O. Box 666
South Florida Water Management District
Belle Glade, FL 33430
P.O. Box 24680
West Palm Beach, FL 33416
David G. Guest, Esq.
Sierra Club Legal Defense Fund
Timothy A. Smith, Esq.
P.O. Box 1329
Assistant General Counsel
Tallahassee, FL 32302
Department of Environmental Protection
Twin Towers Building
Lynn D. Solomon, Esq.
2600 Blair Stone Road, Room 618
Simmons & Solomon
Tallahassee, FL 32399-2400
Fountain Plaza
10020 South Federal Hwy.
Paul L. Nettleton, Esq.
Pt. St. Lucie, FL 34952
Popham Haik
4000 International Place
Timothy D. Searchinger, Esq.
100 S.E. Second Street
Environmental Defense Fund
Miami, Florida 33131
1875 Connecticut Avenue, N.W.
Suite 1016
Rick J. Burgess, Esq.
Washington D.C. 20009
Gunster, Yoakley, Valdes-Fauli
& Stewart, P.A.
Michael Reed, Esq.
500 E. Broward Boulevard, # 1400
General Litigation Section
Ft. Lauderdale, FL 33394
Environment and Natural Resources Div.
U.S. Department of Justice
William Green, Esq.
P.O. Box 663
Hopping, Boyd, Green & Sams, P.A.
Washington, D.C. 20044-0663
123 S. Calhoun
Tallahassee, FL 32301
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