San Francisco Baykeeper v. Premier Recycle Company

Filing 24

STIPULATION AND ORDER continuing Case Management Conference to 10/29/2013 at 01:30 PM in Courtroom 2, 5th Floor, San Jose. Case Management Statement due by 10/22/2013. Signed by Judge Howard R. Lloyd on 9/23/13. (hrllc1, COURT STAFF) (Filed on 9/23/2013)

*E-Filed: September 23, 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 20 21 22 23 24 25 26 27 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, per a previous Stipulation and Order of the Court, the Initial Case Management Conference was continued until September 10, 2013 at 1:30 p.m.; WHEREAS, per a previous Stipulation and Order of the Court, the Initial Case Management Conference was continued until October 1, 2013 at 1:30 p.m.; WHERAS, the Parties submitted ADR certifications and stipulated to ADR process by mediation on September 17, 2013; 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 two (2) weeks; NOW, THEREFORE, THE PARTIES STIPULATE AS FOLLOWS: 1. The Case Management Conference shall be continued to October 22, 2013 at 1:30 pm, or as soon thereafter as the Court is available. 2. The Parties’ Rule 26(f) Report and Joint Case Management Statement shall be due one week before the Case Management Conference. 3. The Parties shall make initial disclosures or state objections in their Rule 26(f) Report no 28 29 30 31 STIPULATION TO CONTINUE CASE MGMT CONFERNCE Civil No. C 13-01695 HRL 1 2 later than one week before the Case Management Conference. Dated: September 20, 2013 3 Respectfully submitted, 4 5 By: /s/ Andrea Kopecky Andrea Kopecky Attorney for Plaintiff SAN FRANCISCO BAYKEEPER 6 7 8 9 10 11 By: /s/ Anna Le May Anna Le May Attorney for Defendant PREMIER RECYCLE 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 GOOD CAUSE APPEARING, October 29, 2013 1. The Case Management Conference shall be continued to___________________ at 1:30 pm. 2. The Parties’ Rule 26(f) Report and Joint Case Management Statement shall be filed no October 22, 2013 later than ________________. 3. The Parties shall make initial disclosures or state objections in their Rule 26(f) Report no October 22, 2013 later than _____________________. IT IS SO ORDERED. 11 12 9/23/13 Date: ______________ NORTHERN DISTRICT OF CALIFORNIA 13 14 15 16 ____________________________________ Honorable Howard R. Lloyd United States District Court 17 18 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