San Francisco Baykeeper v. Premier Recycle Company

Filing 14

STIPULATION AND ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE: Case Management Statement due by 9/3/2013. Case Management Conference continued to 9/10/2013 at 1:30 PM in Courtroom 2, 5th Floor, San Jose. Related deadlines adjusted accordingly. Signed by Magistrate Judge Howard R. Lloyd on August 13, 2013. (hrllc1, COURT STAFF) (Filed on 8/13/2013)

*E-FILED: August 13, 2013* 1 2 3 4 5 6 7 Jayni Foley Hein (Bar No. 258261) Andrea Kopecky (Bar No. 276366) SAN FRANCISCO BAYKEEPER 785 Market Street, Suite 850 San Francisco, California 94103 Telephone: (415) 856-0444 Facsimile: (415) 856-0443 Email: jayni@baykeeper.org Email: andrea@baykeeper.org Attorneys for Plaintiff: BAYKEEPER 8 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 SAN JOSE DIVISION 12 13 14 SAN FRANCISCO BAYKEEPER, a non-profit corporation, 15 16 17 18 19 Plaintiff, v. PREMIER RECYCLE COMPANY, Defendant. Civil No. C 13-01695 HRL STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES; [PROPOSED] ORDER Fed. R. Civ. P. 26(f); L.R. 16-10 Honorable Howard R. Lloyd 20 21 22 23 24 25 26 27 28 29 30 31 STIPULATION TO CONTINUE CASE MGMT CONFERENCE Civil No. C 13-01695-HRL 1 2 3 4 5 6 Plaintiff San Francisco Baykeeper (“Baykeeper”) and Defendant Premier Recycle Company (“Premier Recycle”) in the above-captioned action respectfully submit this stipulation as follows: WHEREAS, Baykeeper and Premier Recycle (collectively, the “Parties”) have been working together in good faith to reach a settlement in this action; WHEREAS, the Parties have already exchanged and are currently finalizing the terms of what they anticipate will be a final Consent Decree for approval by the court; 7 WHEREAS, the Court’s Order Setting Initial Case Management Conference and ADR 8 Deadlines (“Scheduling Order”) set the initial Case Management Conference in this matter for July 23, 9 2013 at 1:30 pm; 10 11 12 13 14 15 16 17 18 19 WHEREAS, per a previous Stipulation and Order of the Court, the Initial Case Management Conference was continued until August 20, 2013 at 1:30 p.m.; WHEREAS, the Scheduling Order states that if the Initial Case Management Conference is continued, the other deadlines are continued accordingly; WHEREAS, the Parties desire to continue negotiating settlement in good faith and anticipate reaching a final settlement in this action within the next four (4) weeks; NOW, THEREFORE, THE PARTIES STIPULATE AS FOLLOWS: 1. The Case Management Conference shall be continued to September 10, 2013 at 1:30 pm, or as soon thereafter as the Court is available. 2. The Parties’ ADR certifications and stipulations to ADR process or notices of need for 20 an ADR phone conference shall be due two weeks before the Case Management 21 Conference. 22 23 24 25 26 3. The Parties’ Rule 26(f) Report and Joint Case Management Statement shall be due one week before the Case Management Conference. 4. The Parties shall make initial disclosures or state objections in their Rule 26(f) Report no later than one week before the Case Management Conference. Dated: August 1, 2013 27 28 29 30 31 STIPULATION TO CONTINUE CASE MGMT CONFERNCE Civil No. C 13-01695 HRL Respectfully submitted, 1 2 By: /s/ Andrea Kopecky Andrea Kopecky Attorney for Plaintiff SAN FRANCISCO BAYKEEPER 3 4 5 6 7 8 By: /s/ Anna Le May Anna Le May Attorney for Defendant PREMIER RECYCLE 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 STIPULATION TO CONTINUE CASE MGMT CONFERNCE Civil No. C 13-01695 HRL [PROPOSED] ORDER 1 2 3 4 5 6 7 8 9 10 11 12 GOOD CAUSE APPEARING, September 10, 2013 1. The Case Management Conference shall be continued to___________________ at 1:30 pm. Related deadlines are adjusted accordingly. 2. The ADR certifications and stipulations to ADR process or notices of need for an ADR phone conference shall be filed no later than ______________. 3. The Parties’ Rule 26(f) Report and Joint Case Management Statement shall be filed no later than ________________. 4. The Parties shall make initial disclosures or state objections in their Rule 26(f) Report no later than _____________________. IT IS SO ORDERED. 13 14 August 13, 2013 Date: ______________ NORTHERN DISTRICT OF CALIFORNIA 15 16 17 18 ____________________________________ Honorable Howard R. Lloyd United States District Court 19 20 21 22 23 24 25 26 27 28 29 30 31 STIPULATION TO CONTINUE CASE MGMT CONFERENCE Civil No. C 13-01695-HRL