California Sportfishing Protection Alliance v. Waste Management of Alameda County, Inc.

Filing 21

STIPULATION AND ORDER Continuing Date of Exchange of Initial Disclosures (tdm, COURT STAFF) (Filed on 12/4/2008)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

MICHAEL R. LOZEAU (State Bar No. 142893) DOUGLAS J. CHERMAK (State Bar No. 233382) Lozeau Drury LLP 1516 Oak Street, Suite 216 Alameda, CA 94501 Tel: [phone] Fax: [phone] (fax) E-mail: [e-mail] [e-mail] ANDREW L. PACKARD (State Bar No. 168690) MICHAEL P. LYNES (State Bar No. 230462) Law Offices of Andrew L. Packard 319 Pleasant Street Petaluma, CA 94952 Tel: [phone] Fax: [phone] E-mail: [e-mail] Attorneys for Plaintiff CALIFORNIA SPORTFISHING PROTECTION ALLIANCE JOHN LYNN SMITH (State Bar No. 154657) JULIA C. BUTLER (State Bar No. 199133) JOONSIK MAING (State Bar No. 240927) Reed Smith LLP 1999 Harrison St., Suite 2400 Oakland, CA 94612-3572 Tel: [phone] Fax: [phone] E-mail: [e-mail] [e-mail] Attorney for Defendant WASTE MANAGEMENT OF ALAMEDA COUNTY, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA CALIFORNIA SPORTFISHING PROTECTION ALLIANCE, a non-profit corporation, Plaintiff, vs. WASTE MANAGEMENT OF ALAMEDA COUNTY, INC., a corporation. Defendant. Case No. 3:08-cv-03497-SC SECOND STIPULATION CONTINUING DATE ON WHICH TO EXCHANGE INITIAL DISCLOSURES; [PROPOSED] ORDER THEREON Judge: Hon. Samuel Conti

1

Case No. 3:08-cv-03497-SC

Second Stipulation Continuing Date on Which to Exchange Initial Disclosures

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 /// ///

WHEREAS, Plaintiff California Sportfishing Protection Alliance served the Complaint in this action on Defendant Waste Management of Alameda County, Inc. ("WMAC") on September 4, 2008;

WHEREAS, Defendant filed its answer in this action on September 30, 2008;

WHEREAS, the parties filed a joint case management conference statement on November 13, 2008;

WHEREAS, both before and after the filing and service of the Complaint, the parties have engaged in and are continuing to engage in discussions and negotiations to fully resolve this matter and have made significant progress on a potential settlement;

WHEREAS, the parties would like to continue to focus their efforts on settlement discussions instead of preparing initial disclosures which may become unnecessary should the parties reach a resolution;

WHEREAS, the parties appeared at the Initial Case Management Conference on November 21, 2008 and represented to the Court that they were making good progress toward settlement;

WHEREAS, the parties agreed to extend the date upon which to exchange initial disclosures from December 5, 2008 to January 9, 2009;

2

Case No. 3:08-cv-03497-SC

Second Stipulation Continuing Date on Which to Exchange Initial Disclosures

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

THEREFORE, IT IS HEREBY STIPULATED by and among Plaintiff California Sportfishing Protection Alliance and Defendant Waste Management of Alameda County, Inc. that the parties shall have to and including January 9, 2009 to exchange initial disclosures.

Dated: December 2, 2008

Respectfully submitted, LOZEAU DRURY LLP By: ___________\s\____________ DOUGLAS J. CHERMAK Attorneys for Plaintiff CALIFORNIA SPORTFISHING PROTECTION ALLIANCE REED SMITH LLP By: ___________\s\_____________ JULIA C. BUTLER Attorneys for Defendant WASTE MANAGEMENT OF ALAMEDA COUNTY, INC.

18 19 20 21 22 23 24 25 26 27 28 3

UNIT ED

S

17

S DISTRICT TE C TA

ER

N

F D IS T IC T O R

Case No. 3:08-cv-03497-SC

Second Stipulation Continuing Date on Which to Exchange Initial Disclosures

A

C

LI

FO

Judge S

o amuel C

nti

R NIA

IT IS S

O ORD

ERED

RT U O

NO

RT

H

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: _______________

ORDER

Pursuant to Stipulation, it is so ORDERED.

_______________________________________ UNITED STATES DISTRICT JUDGE

.

4

Case No. 3:08-cv-03497-SC

Second Stipulation Continuing Date on Which to Exchange Initial Disclosures