Case 8:07-cv-00335-FMC-FMO Document 112 Filed 01/14/2008 Page 1 of 3

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
4 110 West A Street, Suite 1100
San Diego, CA 92101
5 P.O. Box 85266
San Diego, CA 92186-5266
6 Telephone: (619) 645-2023
Fax: (619) 645-2012
7 Email: Jamee.Patterson@doj.ca.gov

8 Attorneys for Intervenor California Coastal Commission

10 IN THE UNITED STATES DISTRICT COURT

11 FOR THE CENTRAL DISTRICT OF CALIFORNIA

12 WESTERN DIVISION

13

14 NATURAL RESOURCES DEFENSE Case No: SACV 07-0335 FMC (FMOx)

COUNCIL, INC., et al.,
15 INTERVENOR CALIFORNIA
Plaintiffs, COASTAL COMMISSION’S JOINDER
16 IN PLAINTIFFS’ OPPOSITION TO
v. DEFENDANTS’ EX PARTE
17 APPLICATION FOR STAY PENDING
DONALD C. WINTER, Secretary of the Navy, APPEAL
18 et al.,
Hearing: n/a
19 Defendants, Time: n/a
Courtroom: 750
20 CALIFORNIA COASTAL COMMISSION, Judge: The Honorable Florence-Marie
Cooper
21 Intervenor.

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23 Intervenor California Coastal Commission joins in plaintiffs’ opposition to defendants

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.

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Case No. SACV 07-0335 FMC (FMOx)

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Case 8:07-cv-00335-FMC-FMO Document 112 Filed 01/14/2008 Page 2 of 3

1 Dated: January 14, 2008

2 Respectfully submitted,

3 EDMUND G. BROWN JR.

Attorney General of the State of California
4 J. MATTHEW RODRIQUEZ
Senior Assistant Attorney General
5

6
/s/ Jamee Jordan Patterson
7 JAMEE JORDAN PATTERSON
Supervising Deputy Attorney General
8 Attorneys for Intervenor

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SD2007304580
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Case No. SACV 07-0335 FMC (FMOx)

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Case 8:07-cv-00335-FMC-FMO Document 112 Filed 01/14/2008 Page 3 of 3

2 DECLARATION OF SERVICE BY U.S. MAIL

3 Case Name: NRDC v. Winter (on remand)

4 Case No.: SACV 07-0335 FMC (FMOx)

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 INTERVENOR CALIFORNIA COASTAL COMMISSION’S JOINDER IN

PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ EX PARTE APPLICATION
12 FOR STAY PENDING APPEAL

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 Guillermo Montero

Irell & Manella US Department of Justice
16 1800 Avenue of the Stars, Ste 900 Environment and Natural Resources Division
Los Angeles, CA 90067-4276 P O Box 663
17 Washington, DC 20044-0663

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 JAMEE J. PATTERSON /s/Jamee J. Patterson

25 Declarant Signature

26 80196242.wpd

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