Stevenson Enterprises v. Mendoza et al
Filing
175
ORDER resetting CMC to 11/13/14 at 10:30 a.m. re 174 Joint Case Management Statement filed by Stevenson Enterprises Case Management Statement due by 11/6/2014. Further Case Management Conference set for 11/13/2014 10:30 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 8/8/14. (bpf, COURT STAFF) (Filed on 8/8/2014)
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John J. Verber, CASB# 139917
jverber@burnhambrown.com
Jack W. Schwartz Jr., CASB #124506
jschwartz@burnhambrown.com
BURNHAM BROWN
A Professional Law Corporation
P.O. Box 119
Oakland, California 94604
--1901 Harrison Street, 14th Floor
Oakland, California 94612
Telephone:
(510) 444-6800
Facsimile:
(510) 835-6666
Email:
jverber@burnhambrown.com
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Attorneys for Plaintiff and Counter-Defendant
STEVENSON ENTERPRISES, a California general
partnership
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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STEVENSON ENTERPRISES, a California
general partnership
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Plaintiff,
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v.
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ENRIQUETA MENDOZA; ESTATE OF
DAVID Z. MENDOZA; HAK CHON LEE;
JEUM SOON LEE; HYSL, Inc., a California
corporation; and YONG W. LEE,
Defendants.
______________________________________
_
No. C 08-4845 EMC
JOINT CASE MANAGEMENT
CONFERENCE STATEMENT,
STIPULATION AND [PROPOSED]
ORDER REGARDING FILING OF
REQUEST FOR ENTRY OF
JUDGMENT AGAINST DEFENDANT
HAK LEE
DATE:
TIME:
COURTROOM:
JUDGE:
August 14, 2014
10:30 a.m.
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Hon. Edward M. Chen
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AND RELATED CROSS-CLAIMS AND
COUNTER-CLAIMS
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Plaintiff STEVENSON ENTERPRISES (“Plaintiff” or “STEVENSON”), and Defendant
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Cross-Claimant and Counter Claimant HAK CHON LEE (“HAK LEE”) file the following Joint
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Joint Case Management Conference Statement, Stipulation and [Proposed] Order
Regarding Filing Of Request For Entry Of Judgment Against Defendant Hak Lee
C 08-4845 EMC
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Case Management Statement and stipulate as follows:
1. HAK LEE has previously stipulated that Plaintiff may obtain a Judgment against
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him.
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2. Since the filing of parties’ last Stipulation and Order Regarding Filing Of Request
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For Entry Of Judgment Against Hak Lee and Order thereon [Case Document 171,
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filed January 24, 2014], Plaintiff has continued to meet with the Alameda County
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Water Agency (“ACWA”), the regulatory agency charged with regulating the cleanup
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of the site, to attempt to obtain a conditional closure (also known as a low risk site
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closure determination) for the site underlying this litigation.
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3. The ACWA required that Plaintiff install and monitor additional vapor wells in areas
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in close proximity to the subject premises which Plaintiff is accomplishing.
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Additional work will be required; however, while Plaintiff has not obtained a
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conditional closure from the ACWA or determined the final amount of its damages to
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be included in a Judgment against HAK LEE, Plaintiff has determined that it is now
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in a position to file a request for a Judgment against HAK LEE for the damages it has
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suffered to date.
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4. Based thereon, Plaintiff and HAK LEE stipulate that Plaintiff shall have up to and
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including September 30, 2014 to file its request for entry of a Judgment against HAK
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LEE.
5. Based on the above, the Parties further request that the Case Management Conference
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currently scheduled for August 14, 2014 at 10:30 a.m. be continued until October 31,
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Joint Case Management Conference Statement, Stipulation and [Proposed] Order
Regarding Filing Of Request For Entry Of Judgment Against Defendant Hak Lee
C 08-4845 EMC
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2014 or a date thereafter convenient to the Court.
IT IS SO STIPULATED:
DATED: August 7, 2014
BURNHAM BROWN
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By:
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DATED: August 7, 2014
_/s/ Jack W. Schwartz Jr.______
JACK W. SCHWARTZ JR.
Attorneys for Plaintiff STEVENSON
ENTERPRISES
__/s/ Brian H. Lee_______________
BRIAN H. LEE
Attorney for Defendant HAK CHON LEE
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Joint Case Management Conference Statement, Stipulation and [Proposed] Order
Regarding Filing Of Request For Entry Of Judgment Against Defendant Hak Lee
C 08-4845 EMC
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CERTIFICATION
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I, Jack W. Schwartz Jr., hereby attest, pursuant to N.D. Cal General Order No. 45, that
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the concurrence to the filing of this document has been obtained from counsel for HAK CHON
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LEE.
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/s/ Jack W. Schwartz Jr.
Jack W. Schwartz Jr.
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ORDER
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The Court, having reviewed the Joint Case Management Conference Statement,
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Stipulation and [Proposed] Order Regarding Filing Of Request For Entry Of Judgment Against
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Defendant Hak Lee, AND FOR GOOD CAUSE APPEARING orders:
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Plaintiff shall have up to and including September 30, 2014 to file its papers in
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support of its Request For Entry Of Judgment Against defendant HAK LEE.
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Nov. 13
2.
A Case Management Conference shall be held on ________________. 2014 at
10:30
_________ a.m. / p.m.
IT IS SO ORDERED.
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dwa
Judge E
ER
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hen
rd M. C
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4822-3150-3900, v. 1
OO
IT IS S
DIFIED
AS MO
R NIA
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The Honorable Edward M. Chen
Judge ofRDERED States District Court
the United
FO
UNIT
ED
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Dated: August ___, 2014
RT
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S DISTRICT
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TA _____________________________
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Joint Case Management Conference Statement, Stipulation and [Proposed] Order
Regarding Filing Of Request For Entry Of Judgment Against Defendant Hak Lee
C 08-4845 EMC
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