United States of America v. LaPant et al

Filing 52

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 12/18/2017 ORDERING 49 Scheduling order amended as follows: Any joinder of parties or amendments to the pleadings shall be filed by 2/9/2018; Except with respect to economic bene fit and economic impact, the parties shall provide "opening expert reports" by 2/23/2018; Except with respect to economic benefit and economic impact, the parties shall provide "responsive expert reports" by 4/27/2018; With respec t to economic benefit and economic impact, "opening expert reports" are due to be served no later than 3/26/2018; and "responsive expert reports" are due to be served no later than 5/25/2018. In all other respects, the Scheduling Order remains in effect. (Washington, S)

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DOWNEY BRAND LLP
ROBERT P. SORAN
ASHLEY M. BOULTON
621 Capitol Mall, 18th Floor
Sacramento, CA 95814-4731
Telephone: [phone] / Facsimile: [phone]
Attorneys for Defendants
GOOSE POND AG, INC., and FARMLAND MANAGEMENT SERVICES
CANNATA, O’TOOLE, FICKES & ALMAZAN
THERESE Y. CANNATA
KIMBERLY A. ALMAZAN
100 Pine Street, Suite 350
San Francisco, CA 94111
Telephone: [phone] / Facsimile: 415.409.8904
Attorneys for Defendants
ROGER J. LAPANT, JR. and J&J FARMS
JEFFREY H. WOOD
Acting Assistant Attorney General
ANDREW J. DOYLE
JOHN THOMAS H. DO
United States Department of Justice
Environmental and Natural Resources Division
P.O. Box 7611
Washington, DC 20044
Telephone: [phone] (Doyle), [phone] (Do)
PHILLIP A. TALBERT
United States Attorney
GREGORY T. BRODERICK
Assistant United States Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: [phone]
Attorneys for the UNITED STATES OF AMERICA

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Case No. 2:16-cv-01498-KJM-DB
Plaintiff,
JOINT STIPULATION, MOTION, AND
v.
ORDER TO AMEND
ROGER J. LAPANT, JR., et al.,
Defendants.

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Joint Motion to Amend Schedule

Case No. 2:16-cv-01498-KJM-DB

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The Parties to this action—Plaintiff United States of America and Defendants Roger J.

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LaPant, J&J Farms, Goose Pond Ag, Inc., and Farmland Management Services (collectively,

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unless specially noted, “Defendants”)—have conferred and hereby provide this stipulation,

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motion, and proposed order to amend the Court’s “Order and amendment to the Scheduling

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Order,” filed June 7, 2017 (ECF No. 49) (“Scheduling Order”).

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1.

Scheduling Order:

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a.

b.

Except with respect to economic benefit and economic impact, the parties

shall provide “opening expert reports” by February 23, 2018.

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Any joinder of parties or amendments to the pleadings shall be filed by

February 9, 2018.

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The parties stipulate and move to amend the following deadlines set forth in the

c.

Except with respect to economic benefit and economic impact, the parties

shall provide “responsive expert reports” by April 27, 2018.

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d.

With respect to economic benefit and economic impact, “opening expert

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reports” are due to be served no later than March 26, 2018 and “responsive expert reports” are

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due to be served no later than May 25, 2018.

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2.

In all other respects, the Scheduling Order remains in effect.

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STIPULATED AND RESPECTFULLY SUBMITTED,
DOWNEY BRAND LLP
DATED: December 12, 2017
By: /s/ Robert P. Soran
ROBERT P. SORAN
Attorneys for Defendants GOOSE POND AG, INC.,
and FARMLAND MANAGEMENT SERVICES

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CANNATA, O’TOOLE, FICKES & ALMAZAN LLP

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By: /s/ Therese Y. Cannata
THERESE Y. CANNATA
Attorneys for Defendants ROGER J. LAPANT, Jr.,
and J&J FARMS

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Joint Motion to Amend Schedule

No. 2:16-cv-01498-KJM-DB
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PHILLIP A. TALBERT
United States Attorney
By: /s/ John Thomas Do
JOHN THOMAS DO
Assistant United States Attorney

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ORDER
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Upon due consideration, the Court approves and enters the foregoing stipulation and
motion as an Order and amendment to the Scheduling Order (ECF No. 49).
DATED: December 18, 2017.

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UNITED STATES DISTRICT JUDGE

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Joint Motion to Amend Schedule

No. 2:16-cv-01498-KJM-DB
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