Baykeeper, Inc v. City of San Bruno

Filing 22

STIPULATION AND ORDER Case Management Conference set for 6/10/2011 10:00 AM in Courtroom 1, 17th Floor, San Francisco before Hon. Samuel Conti.. Signed by Judge Samuel Conti on 4/28/11. (tdm, COURT STAFF) (Filed on 4/28/2011)

1 Kenton L. Alm (SBN: 59017)
[e-mail]
2 Sabrina Wolfson (SBN: 248444)
[e-mail]
3 MEYERS, NAVE, RIBACK, SILVER & WILSON
555 12th Street, Suite 1500
4 Oakland, California 94607
Telephone: [phone]
5 Facsimile: [phone]
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Attorneys for Defendant, City of San Bruno
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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BAYKEEPER, INC., d/b/a SAN
12 FRANCISCO BAYKEEPER, a California
non-profit corporation,
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Plaintiff,
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v.
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CITY OF SAN BRUNO, a California
16 municipal corporation,
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CASE NO. CV 10-00753 SC
STIPULATION AND [PROPOSED]
ORDER CONTINUING APRIL 29, 2011
CASE MANAGEMENT CONFERENCE

Defendant.

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WHEREAS, the parties in this case are scheduled to attend a Case Management
Conference before this Court on April 29, 2011, at 10:00 a.m.;

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WHEREAS, the parties have reached general agreement on the terms of a consent decree
and are in the process of resolving the two remaining issues;

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WHEREAS, the parties anticipate that they will finalize the consent decree by June 10,
2011, and therefore a Case Management Conference is not necessary at this time.

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WHEREAS, the parties desire to continue the Case Management Conference to June 10,
2011.
NOW, THEREFORE, the undersigned parties hereby stipulate that:

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10-00753 SC
STIPULATION AND [PROPOSED] ORDER CONTINUING APRIL 29, 2011 CASE MANAGEMENT
CONFERENCE

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1.

The Case Management Conference currently set for April 29, 2011, will be

2 continued until June 10, 2011 at 10:00 a.m. to allow the parties time to finalize the consent decree.
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2.

The parties shall file a joint case management conference statement by no later than

4 June 3, 2011 advising the Court as to their progress in finalizing the consent decree and the need
5 for a Case Management Conference.
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7 DATED: April 29, 2011

MEYERS, NAVE, RIBACK, SILVER & WILSON

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By:

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/s/ Sabrina S. Wolfson
Sabrina S. Wolfson
Attorneys for Defendant, City of San Bruno

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ENVIRONMENTAL ADVOCATES
DATED: April 29, 2011

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By:
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/s/ Christopher A. Sproul
Christopher A. Sproul
Attorneys for Plaintiff, Baykeeper, Inc., d/b/a San
Francisco Baykeeper

1635874.1

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onti

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Judge S

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________________________________
IT IS S
U.S. District Judge
NO

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By:

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4/28/11

22 Date: ______________________

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
UNIT
ED

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[PROPOSED] ORDER

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F
D IS T IC T O
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10-00753 SC
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STIPULATION AND [PROPOSED] ORDER CONTINUING APRIL 29, 2011 CASE MANAGEMENT
CONFERENCE

1 Kenton L. Alm (SBN: 59017)
[e-mail]
2 Sabrina Wolfson (SBN: 248444)
[e-mail]
3 MEYERS, NAVE, RIBACK, SILVER & WILSON
555 12th Street, Suite 1500
4 Oakland, California 94607
Telephone: [phone]
5 Facsimile: [phone]
6 Attorneys for Defendant
CITY OF SAN BRUNO
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8
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

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BAYKEEPER, INC., d/b/a SAN
12 FRANCISCO BAYKEEPER, a California
non-profit corporation,
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Plaintiff,
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v.
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THE CITY OF SAN BRUNO, a municipal
16 corporation,
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CASE NO.: CV 10-00753 SC
DECLARATION OF SABRINA S.
WOLFSON ATTESTING
CONCURRENCE OF PLAINTIFF TO
STIPULATION AND [PROPOSED]
ORDER

Defendant.

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I, Sabrina S. Wolfson, declare as follows:
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1.

I am an attorney at law duly licensed to practice before the Courts of the State of

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California and registered with the United States District Court, Northern District for e-filing, and
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an Associate at Meyers, Nave, Riback, Silver & Wilson, attorneys of record for Defendant City of
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San Bruno (“City”). If called to testify, I could competently testify as to the facts within this
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Declaration, based on my personal knowledge.
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2.

The parties wish to file the Stipulation and [Proposed] Order Continuing the April

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29, 2011 Case Management Conference today, April 28, 2011.
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3.

On April 28, 2011, Christopher Sproul, Counsel for Plaintiff, Baykeeper, Inc., d/b/a

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San Francisco Baykeeper (“Baykeeper”) indicated to me by telephone that we have permission to
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CV 10-00753 SC
1
DECLARATION OF SABRINA S. WOLFSON ATTESTING CONCURRENCE OF PLAINTIFF TO
STIPULATION AND [PROPOSED] ORDER

1 file the Stipulation and [Proposed] Order on Baykeeper’s collective behalf.
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4.

He also indicated to me that Baykeeper concurred with the contents of the

3 Stipulation and [Proposed] Order as filed herewith.
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I declare under penalty of perjury under the laws of the United States that the foregoing is

5 true and accurate. Executed on April 28, 2011, at Oakland, California.
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____/s/ Sabrina S. Wolfson___
Sabrina S. Wolfson

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CV 10-00753 SC

DECLARATION OF SABRINA S. WOLFSON ATTESTING CONCURRENCE OF PLAINTIFF TO
STIPULATION AND [PROPOSED] ORDER