California River Watch v. County of Madera

Filing 15

STIPULATION and ORDER GRANTING the parties' request for an extension of the exchange of initial disclosures deadline to 7/10/2014. Order signed by Magistrate Judge Sandra M. Snyder on 6/3/2014. (Rooney, M)

1 Jack Silver, Esq. SB #160575
E-mail: [e-mail]
2 Law Office of Jack Silver
Post Office Box 5469
3 Santa Rosa, CA 95402-5469
Tel. [phone]
4 Fax. [phone]
5 David J. Weinsoff, Esq. SBN 141372
Email: [e-mail]
6 Law Office of David J. Weinsoff
138 Ridgeway Avenue
7 Fairfax, CA 94930
Tel. [phone]
8 Fax. [phone]
9 Attorneys for Plaintiff
CALIFORNIA RIVER WATCH
10
11 McCormick, Barstow, Sheppard,
Wayte & Carruth LLP
12 Matthew E. Fletcher, #198028
[e-mail]
13 Melody A. Hawkins, #226522
[e-mail]
14 7647 North Fresno Street
Fresno, California 93720
15 Telephone:
[phone]
Facsimile:
[phone]
16
Attorneys for Defendant
17 COUNTY OF MADERA
18
19

UNITED STATES DISTRICT COURT

20

EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION

21 CALIFORNIA RIVER WATCH,

Case No. 1:13-CV-01893-AWI-SMS

22

STIPULATION OF THE PARTIES
REGARDING EXTENDING TIME TO
EXCHANGE RULE 26 INITIAL
DISCLOSURES AND
ORDER THEREON

23

Plaintiff,
v.

24 COUNTY OF MADERA,
25

Defendant.
STIPULATION OF THE PARTIES

26
27

1.

Pursuant to Scheduling Conference Order issued in the above-captioned case, Plaintiff

28 CALIFORNIA RIVER WATCH (“Plaintiff”) and Defendant COUNTY OF MADERA (“Defendant”)
MCCORMICK, BARSTOW,
SHEPPARD, W AYTE &
CARRUTH LLP
7647 NORTH FRESNO STREET
FRESNO, CA 93720

STIPULATION TO EXTEND TIME TO MAKE RULE 26 INITIAL DISCLOSURES AND [PROPOSED]
ORDER THEREON

1 (collectively referred to herein as the “PARTIES”) are to exchange their respective Initial Disclosures
2 required by Fed. R. Civ. P. 26(a)(1) on or before June 4, 2014.
3

2.

The PARTIES are actively working towards the resolution of this action by settlement.

4 (Declaration of Melody A. Hawkins Regarding Good Cause To Extend Time To Make Rule 26 Initial
5 Disclosures submitted concurrently herewith as Exhibit “A” and incorporated herein by reference
6 (“Hawkins Decl.”) , ¶ 4.) The PARTIES acknowledge and agree, however, that additional time is
7 needed in order to finalize the terms of the settlement. (Id. at ¶ 7.)
8

3.

The PARTIES acknowledge and agree that in light of the fact that they are actively

9 working towards the resolution of this action by settlement, good cause exists for extending the time
10 to exchange their respective Rule 26(a)(1) Initial Disclosures. The PARTIES acknowledge and agree
11 that such extension will allow them the additional time necessary to work towards settlement and
12 potentially avoid incurring any additional time or expense in the preparation of their respective Initial
13 Disclosures. (Hawkins Decl., ¶ 7.)
14

4.

Accordingly, pursuant to Fed. R. Civ. P. 26(a)(1)(C), the PARTIES, by and through

15 their counsel of record, have agreed and stipulated to extend the deadline for the exchange of their
16 respective Rule 26(a)(1) Initial Disclosures to Thursday, July 10, 2014. (Id.)
17

IT IS SO AGREED.

18
Respectfully submitted,

19 Dated: June 2, 2014
20

LAW OFFICE OF JACK SILVER

21
22

/s/ Jack Silver
Jack Silver
Attorneys for Plaintiff CALIFORNIA RIVER
WATCH

By:
23
24
25
26

Signatures continued on page 3.

27
28
MCCORMICK, BARSTOW,
SHEPPARD, W AYTE &
CARRUTH LLP
7647 NORTH FRESNO STREET
FRESNO, CA 93720

2
STIPULATION TO EXTEND TIME TO MAKE RULE 26 INITIAL DISCLOSURES AND [PROPOSED]
ORDER THEREON

Respectfully submitted,

1 Dated: June 2, 2014
2

LAW OFFICE OF DAVID J. WEINSOFF

3
4

/s/ David J. Weinsoff
David J. Weinsoff
Attorneys for Plaintiff CALIFORNIA RIVER
WATCH

By:
5
6
7
8

Respectfully submitted,

9 Dated: June 2, 2014

McCORMICK, BARSTOW, SHEPPARD,
WAYTE & CARRUTH LLP

10
11
12

/s/ Matthew E. Fletcher
Matthew E. Fletcher
Attorneys for Defendant COUNTY OF MADERA
By:

13
14
15
16

IT IS SO ORDERED.

17
18
DATED: 6/4/2014

/s/ SANDRA M. SNYDER
UNITED STATES MAGISTRATE JUDGE

19
20

54322-00034 2956187.1

21
22
23
24
25
26
27
28
MCCORMICK, BARSTOW,
SHEPPARD, W AYTE &
CARRUTH LLP
7647 NORTH FRESNO STREET
FRESNO, CA 93720

3
STIPULATION TO EXTEND TIME TO MAKE RULE 26 INITIAL DISCLOSURES AND [PROPOSED]
ORDER THEREON