United States of America v. Fix et al

Filing 11

STIPULATION AND ORDER continuing the Case Management Conference to 3/2/2009 at 01:30 PM. Signed by Judge Thelton E. Henderson on 01/15/09. (rbe, COURT STAFF) (Filed on 1/16/2009)

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JOSEPH P. RUSSONIELLO (SBN 44332) United States Attorney JOANN M. SWANSON (SBN 135879) Chief, Civil Division JONATHAN U. LEE (SBN 148792) Assistant United States Attorney 450 Golden Gate Avenue, 9th Floor San Francisco, California 94102 Telephone: [phone] Facsimile: 415-436-6748 ATTORNEYS FOR UNITED STATES OF AMERICA IN THE UNITED STATES DISTRICT COURT

9 FOR THE NORTHERN DISTRICT OF CALIFORNIA 10 SAN FRANCISCO DIVISION 11 UNITED STATES OF AMERICA, 12 Plaintiff, 13 v. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2. KARLA A. FIX, PETER CHRISTOPHER KIRSCH, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) No. 08-3674 TEH STIPULATION OF THE PARTIES TO REQUEST A THIRTY DAY CONTINUANCE OF THE CASE MANAGEMENT CONFERENCE TO ALLOW FOR CONSUMMATION OF SETTLEMENT; PROPOSED ORDER

This Stipulation and Proposed Order Regarding Settlement (hereinafter, "Stipulation") is entered into by the United States of America, acting through the United States Attorney's Office for the Northern District of California and on behalf of the United States Department of Agriculture, Forest Service (collectively, "the United States"), on the one hand, and defendants Karla A. Fix and Peter Christopher Kirsch, on the other hand, through their authorized representative(s). The Parties stipulate as follows: 1. There is a pending Case Management Conference scheduled for January 26, 2009, at 1:30 p.m. and the parties' joint statement is due January 16, 2009. The parties' counsel of record recently agreed to settlement terms in principle and drafted a stipulation of settlement, which is currently being circulated for signatures by the parties, a process which counsel of record believe will be completed shortly. 1

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3.

In the interest of both judicial economy and the avoidance of unnecessary expenditure for the parties, the parties request that the pending Case Management Conference be postponed to February 23, 2009, or a date in late February or early March convenient to the Court's calendar, and that the joint statement deadline be delayed to correspond to the new date for the Case Management Conference.

IT IS SO STIPULATED.

Dated: January 15, 2009

JOSEPH P. RUSSONIELLO United States Attorney By: /s/ JONATHAN U. LEE Assistant U.S. Attorney

Dated: January 15, 2009

TREMBATH, DEICHLER & HERMANSON, LLP

/s/ Robin Y. Trembath, Esq. Attorneys for Defendants Karla A. Fix and Peter Christopher Kirsch

(PROPOSED) ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. The Case Management Conference March 2 is postponed to February 23, 2009 at 1:30 p.m. and the parties are to file a joint statement seven days beforehand.

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Date: January 15 2009 __,

S DISTRICT TE C ___TA_________________________________ __
HONORABLE THELTON E. HENDERSON United States District Judge

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