California Sportfishing Protection Alliance v. Beard

Filing 7

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr. on 7/4/2013 ORDERING that this matter is STAYED for all purposes except settlement negotiations and related activities until sixty (60) days from the date of this Order. The Status Confe rence presently scheduled for 7/22/2013 at 9:00 a.m. in Courtroom 10 is hereby CONTINUED to 10/28/2013 at 9:00 a.m. in Courtroom 10. A joint status report shall be filed fourteen days prior to the hearing. All other filings and/or requirements in the Federal Rules of Civil Procedure and the Local Rules related to or triggered by the 7/22/2013 Status Conference, if any, are hereby CONTINUED to new dates based on the new Status Conference date herein. CASE STAYED. (Zignago, K.)

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ANDREW L. PACKARD (SBN 168690)
LAURIE A. MIKKELSEN (SBN 260313)

Law Offices of Andrew L. Packard
100 Petaluma Blvd. N., Suite 301
Petaluma, CA 94952
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Plaintiff
California Sportfishing Protection Alliance
KAMALA D. HARRIS
Attorney General of California
ROBERT W. BYRNE
Senior Assistant Attorney General
GAVIN G. MCCABE
Supervising Deputy Attorney General
ELLYN S. LEVINSON (SBN 77176)
DANIEL S. HARRIS (SBN 157433)
Deputy Attorneys General
455 Golden Gate Avenue, 11th Floor
San Francisco, CA 94102
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendant Jeffrey Beard, in his official
Capacity as Secretary of the California Department of
Corrections and Rehabilitation

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CALIFORNIA SPORTFISHING
PROTECTION ALLIANCE, a non-profit
corporation,

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Plaintiff,

Case No. 2:13-CV-00840-GEB-DAD
STIPULATION AND [PROPOSED]
ORDER FOR STAY
(Federal Water Pollution Control Act,
33 U.S.C. § 1251 et seq.)

vs.
JEFFREY BEARD, in his official capacity
as Secretary of the California Department of
Corrections and Rehabilitation,

Defendant.

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STIPULATION AND [PROPOSED] ORDER FOR STAY

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CASE NO. 2:13-CV-00840-GEB-DAD

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Plaintiff California Sportfishing Protection Alliance and Defendant Jeffrey Beard, in his official

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capacity as Secretary of the California Department of Corrections and Rehabilitation, hereby stipulate

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to and respectfully request that, pursuant to the following terms, the Court order a stay of all

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proceedings in this case. The parties so stipulate to conserve their resources pending settlement

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negotiations to address the discharges alleged in the Complaint.

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Pursuant to this stipulation and order, and without waiving any rights, claims or defenses the

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parties may have as of the date of this stipulation, the parties agree that, except for settlement

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negotiations and related activities (e.g., voluntary exchange of information and site visits), the above-

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captioned matter is stayed for all purposes for sixty (60) days from the date of the Court’s order. This

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stay may be extended by stipulation or motion.

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The parties also agree, subject to Court approval, (1) to continue the Status Conference

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presently scheduled for July 22, 2013 at 9:00 a.m. in Courtroom 10 to October 21, 2013 at 9:00 a.m. in

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Courtroom 10 of the above court, or to such date and time thereafter that is convenient for the Court;

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(2) that the Joint Status Conference Report presently due by July 8, 2013 shall be filed by October 7,

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2013; and (3) to continue all other filings and/or requirements in the Federal Rules of Civil Procedure

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and the Local Rules related to or triggered by the July 22, 2013 Status Conference, if any, to new dates

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based on the new Status Conference date herein.

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Respectfully submitted,

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Dated: July 1, 2013

LAW OFFICES OF ANDREW L. PACKARD
_/s/ Andrew L. Packard
________
By: Andrew L. Packard
(As authorized on June 30, 2013 – L.R. 131(e))
Attorneys for Plaintiff
California Sportfishing Protection Alliance

Dated: July 1, 2013

OFFICE OF THE ATTORNEY GENERAL
_/s/ Daniel S. Harris ______________________
By: Daniel S. Harris
Attorneys for Defendant
Jeffrey Beard, in his official capacity as Secretary
of the California Department of Corrections and
Rehabilitation

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STIPULATION AND [PROPOSED] ORDER FOR STAY

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CASE NO. 2:13-CV-00840-GEB-DAD

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Pursuant to the above Stipulation of the parties, IT IS HEREBY ORDERED AS FOLLOWS:

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1.

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This matter is stayed for all purposes except settlement negotiations and related

activities until sixty (60) days from the date of this Order.

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2.

The Status Conference presently scheduled for July 22, 2013 at 9:00 a.m. in Courtroom

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10 is hereby continued to October 28, 2013 at 9:00 a.m. in Courtroom 10 of the above court. A joint

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status report shall be filed fourteen days prior to the hearing. All other filings and/or requirements in

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the Federal Rules of Civil Procedure and the Local Rules related to or triggered by the July 22, 2013

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Status Conference, if any, are hereby continued to new dates based on the new Status Conference date

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herein.

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Date: 7/4/2013

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___________________________________
GARLAND E. BURRELL, JR.
Senior United States District Judge

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DEAC_Signature-END:

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STIPULATION AND [PROPOSED] ORDER FOR STAY

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CASE NO. 2:13-CV-00840-GEB-DAD