Case 8:07-cv-00335-FMC-FMO

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1 EDMUND G. BROWN JR. Attorney General of the State of California 2 J. MATTHEW RODRIQUEZ Senior Assistant Attorney General 3 JAMEE JORDAN PATTERSON, State Bar No. 100967 Supervising Deputy Attorney General 110 West A Street, Suite 1100 4 San Diego, CA 92101 P.O. Box 85266 5 San Diego, CA 92186-5266 Telephone: (619) 645-2023 6 Fax: (619) 645-2012 Email: Jamee.Patterson@doj.ca.gov 7 8 Attorneys for Intervenor California Coastal Commission 9 10 11 12 13 14 15 Plaintiffs, 16 v. 17 18 19 20 21 22 23 Intervenor California Coastal Commission joins in plaintiffs’ opposition to defendants DONALD C. WINTER, Secretary of the Navy, et al., Defendants, CALIFORNIA COASTAL COMMISSION, Intervenor. NATURAL RESOURCES DEFENSE COUNCIL, INC., et al., Case No: SACV 07-0335 FMC (FMOx) INTERVENOR CALIFORNIA COASTAL COMMISSION’S JOINDER IN PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ EX PARTE APPLICATION FOR STAY PENDING APPEAL Hearing: n/a Time: n/a Courtroom: 750 Judge: The Honorable Florence-Marie Cooper IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION

24 ex parte application for a stay pending appeal. For the reasons articulated by plaintiffs in the 25 redacted version of their opposition served on the Commission, defendants’ application for a stay 26 pending appeal should be denied. 27 28
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Case 8:07-cv-00335-FMC-FMO

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Dated: January 14, 2008 Respectfully submitted, EDMUND G. BROWN JR. Attorney General of the State of California J. MATTHEW RODRIQUEZ Senior Assistant Attorney General

/s/ Jamee Jordan Patterson JAMEE JORDAN PATTERSON Supervising Deputy Attorney General Attorneys for Intervenor

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1 2 3 Case Name: 4 Case No.: 5 I declare: 6 I am employed in the Office of the Attorney General, which is the office of a member of the California State Bar, at which member's direction this service is made. I am 18 years of age or 7 older and not a party to this matter. I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United 8 States Postal Service. In accordance with that practice, correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States 9 Postal Service that same day in the ordinary course of business. 10 On January 14, 2008 I served the attached 11 12 INTERVENOR CALIFORNIA COASTAL COMMISSION’S JOINDER IN PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ EX PARTE APPLICATION FOR STAY PENDING APPEAL DECLARATION OF SERVICE BY U.S. MAIL NRDC v. Winter (on remand) SACV 07-0335 FMC (FMOx)

13 by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the internal mail collection system at the Office of the Attorney General at 110 West A Street, 14 Suite 1100, P.O. Box 85266, San Diego, CA 92186-5266, addressed as follows: 15 Alan J Heinrich Irell & Manella 16 1800 Avenue of the Stars, Ste 900 Los Angeles, CA 90067-4276 17 18 Andrew Elsas Wetzler 19 Natural Resources Defense Council 1314 2nd St 20 Santa Monica, CA 90401 21 I declare under penalty of perjury under the laws of the State of California the foregoing is true 22 and correct and that this declaration was executed on January 14, 2008, at San Diego, California. 23 24 25 26 27 28
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Guillermo Montero US Department of Justice Environment and Natural Resources Division P O Box 663 Washington, DC 20044-0663

JAMEE J. PATTERSON Declarant

/s/Jamee J. Patterson Signature