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

Filing 24

STIPULATION AND ORDER to continue discovery deadlines pending mediation. Signed by Judge Samuel Conti on 1/7/09. (tdm, COURT STAFF) (Filed on 1/7/2009)

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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.
Stipulation to Continue Discovery Deadlines Pending Mediation; [Proposed] Order Case No. 3:08-cv-03497-SC

Case No. 3:08-cv-03497-SC STIPULATION TO CONTINUE DISCOVERY DEADLINES PENDING MEDIATION; [PROPOSED] ORDER Judge: Hon. Samuel Conti

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I.

REQUEST AND STIPULATION RE CONTINUING DISCOVERY DEADLINES 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 conferred in an ADR conference call on December 17, 2008, with Daniel Bowling, an ADR Program Staff Attorney for the Northern District of California, and decided to engage in a mediation to be scheduled during January 2009 to help reach a settlement; WHEREAS, the parties agreed to extend the deadlines for all written discovery, including both the initial disclosures and the written discovery that has already been served, to February 25, 2009, in order to focus their efforts on the mediation settlement discussions; WHEREAS, the parties agreed to schedule and conduct a Rule 34 site inspection within two weeks of the mediation should the mediation not result in a settlement; 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 February 25, 2009 to complete pending written discovery and /// /// /// /// /// ///
Stipulation to Continue Discovery Deadlines Pending Mediation; [Proposed] Order

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

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initial disclosures, and that a Rule 34 site inspection shall take place within two weeks of an unsuccessful mediation.

Dated: January 6, 2009 Respectfully submitted, LOZEAU DRURY LLP By: _/s/ Douglas J. Chermak_______ DOUGLAS J. CHERMAK Attorneys for Plaintiff CALIFORNIA SPORTFISHING PROTECTION ALLIANCE REED SMITH LLP By: _/s/ Julia C. Butler (as authorized on 1/6/09)_ JULIA C. BUTLER Attorneys for Defendant WASTE MANAGEMENT OF ALAMEDA COUNTY, INC.

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ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED.
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Stipulation to Continue Discovery Deadlines Pending Mediation; [Proposed] Order

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

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Hon. Samuel Conti RED ORDE United IStatesODistrict Court Judge T IS S
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1/6/09 Dated: _____________

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