San Francisco Baykeeper v. Premier Recycle Company

Filing 27

STIPULATION AND ORDER (MODIFIED) re 25 TO CONTINUE CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES filed by Premier Recycle Company. Case Management Statement due by 11/12/2013. Case Management Conference set for 11/19/2013 01:30 PM in Courtroom 2, 5th Floor, San Jose. Signed by Judge Howard R. Lloyd on 10/22/2013. (hrllc1, COURT STAFF) (Filed on 10/22/2013)

1 6 7 *E-Filed: October 22, 2013* William W. Funderburk Jr. (SBN 176244) Anna L. Le May (SBN 258312) CASTELLÓN & FUNDERBURK LLP 811 Wilshire Boulevard, Suite 1025 Los Angeles, California 90017 Telephone: (213) 623-7515 Facsimile: (213) 532-3984 wfunderburk@candffirm.com alemay@candffirm.com Attorneys for Defendant Premier Recycle Company 2 3 4 5 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 Plaintiff, v. PREMIER RECYCLE COMPANY, Defendant. Civil No. C 13-01695 HRL STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES; [PROPOSED] ORDER (MODIFIED) Fed. R. Civ. P. 26(f); L.R. 16-10 19 20 Honorable Howard R. Lloyd 21 22 23 24 25 26 27 28 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 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; WHEREAS, per a previous Stipulation and Order of the Court, the Initial Case Management Conference was continued until October 29, 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 three (3) weeks; NOW, THEREFORE, THE PARTIES STIPULATE AS FOLLOWS: 1. The Case Management Conference shall be continued to November 19, 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. 27 28 STIPULATION TO CONTINUE CASE MGMT CONFERNCE Civil No. C 13-01695 HRL 1 2 3 3. 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: October 17, 2013 4 Respectfully submitted, 5 6 By: /s/ Anna Le May Anna Le May Attorney for Defendant PREMIER RECYCLE By: /s/ Andrea Kopecky Andrea Kopecky Attorney for Plaintiff SAN FRANCISCO BAYKEEPER 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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, 1. The Case Management Conference shall be continued to___________________ at 1:30 November 19, 2013 pm. 2. The Parties’ Rule 26(f) Report and Joint Case Management Statement shall be filed no November 12, 2013 later than ________________. 3. The Parties shall make initial disclosures or state objections in their Rule 26(f) Report no later than _____________________.* November 12, 2013 IT IS SO ORDERED. 11 12 Date: ______________ 10/22/13 NORTHERN DISTRICT OF CALIFORNIA 13 14 15 16 ____________________________________ Honorable Howard R. Lloyd United States District Court 17 18 *The Court does not intend to grant further continuances of the case management conference. 19 20 21 22 23 24 25 26 27 28 STIPULATION TO CONTINUE CASE MGMT CONFERENCE Civil No. C 13-01695-HRL