(PS) Bullivant v. U.S. Dept. of Agriculture et al

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STIPULATION AND PROPOSED O RDER FOR STAYING CASE
AND M ODIFYING PRETRIAL SCHEDULING O RDER
Melanie Bullivant
P.O. Box 105
Aguilar, CO 81020
(719) 680-8500
MelanieBullivant@use.startmail.com
Plaintiff
ERIC GRANT
United States Attorney
JOSEPH FRUEH
Assistant United States Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
E-mail: 	joseph.frueh@usdoj.gov
Telephone: (916) 554-2702
Facsimile: 	(916) 554-2900
Attorneys for Defendant
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
MELANIE BULLIVANT,
Plaintiff,
v.
UNITED STATES OF AMERICA,
Defendant.
No. 2:24-cv-01883-CSK
STIPULATION AND PROPOSED ORDER
FOR STAYING CASE AND MODIFYING
PRETRIAL SCHEDULING ORDER (ECF 29)
DUE TO LAPSE IN APPROPRIATIONS
IT IS HEREBY STIPULATED, by and between the parties and subject to Court approval, and in
light of the current lapse in appropriations to the Department of Justice, that (1) this action be stayed
pending the restoration of appropriations or the enactment of a continuing resolution, and (2) the parties
submit a joint stipulation and proposed order modifying the current Pretrial Scheduling Order (see
ECF 29) within seven days of the restoration of appropriations or the enactment of a continuing
resolution. The reasons for this stipulation are as follows.

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STIPULATION AND PROPOSED O RDER FOR STAYING CASE
AND M ODIFYING PRETRIAL SCHEDULING O RDER
1. 	At the end of the day on September 30, 2025, the appropriations that have been funding
the Department of Justice expired and appropriations to the Department lapsed. The Department does
not know when funding will be restored by Congress.
2. 	Absent an appropriation or continuing resolution, Department of Justice attorneys are
prohibited from working, even on a voluntary basis, except in limited circumstances, including
“emergencies involving the safety of human life or the protection of property.” 31 U.S.C. § 1342. That
exception is not deemed to include most civil cases.
3. 	Based on the foregoing, the parties respectfully submit that there is good cause to stay
this action pending the restoration of appropriations or the enactment of a continuing resolution, and to
direct the parties submit a joint stipulation and proposed order modifying the current Pretrial Scheduling
Order within seven days of the restoration of appropriations or the enactment of a continuing resolution.
Respectfully submitted,
Dated: 	See original signed stipulation at ECF 42
MELANIE BULLIVANT
Plaintiff
Dated: 	ERIC GRANT
United States Attorney
By: 	See original signed stipulation at ECF 42
JOSEPH FRUEH
Assistant United States Attorney
Attorneys for Defendant
IT IS SO ORDERED
Dated: 11/10/25
4, bull1883.24