Global Community Monitor v. Alameda County Industries Inc

Filing 7

ORDER RESETTING CMC re 6 Proposed Order filed by Global Community Monitor. Signed by Judge Edward M. Chen on 6/13/11. (bpf, COURT STAFF) (Filed on 6/13/2011)

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1 2 3 4 5 6 7 8 Michael R. Lozeau (State Bar No. 142893) Richard T. Drury (State Bar No. 163559) Douglas J. Chermak (State Bar No. 233382) LOZEAU DRURY LLP 1516 Oak Street, Suite 216 Alameda, CA 94501 Tel: (510) 749-9102 Fax: (510) 749-9103 (fax) E-mail: michael@lozeaudrury.com richard@lozeaudrury.com doug@lozeaudrury.com Attorneys for Plaintiff GLOBAL COMMUNITY MONITOR UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 11 GLOBAL COMMUNITY MONITOR, a non-profit corporation, 12 Plaintiff, 13 14 15 vs. Case No. 11-00976 REQUEST AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT STATEMENT ALAMEDA COUNTY INDUSTRIES, INC., a corporation, Defendant. 16 17 On March 2, 2011, Plaintiff filed its complaint in the above-entitled action. On June 9, 2011, 18 19 20 Plaintiff completed its service by filing the waiver of service form. Defendant has until August 8, 2011 to file its answer. During the past few months, the parties have been negotiating a settlement agreement in lieu 21 22 23 of moving forward with the litigation. The parties have reached a tentative agreement on most of the key issues and should complete negotiations and finalize a settlement within the next few weeks. In order to give the parties ample time to complete a settlement agreement and submit it for a 24 25 26 27 28 45-day review period to the Environmental Protection Agency and Department of Justice pursuant to 40 C.F.R. ยง 135.5, Plaintiff requests that the Case Management Conference currently scheduled for June 15, 2011, be continued to September 9, 2011, at 9:00 am. /// REQUEST TO CONTIUNE CASE MANAGEMENT CONFERENCE 1 11-00976 1 Dated: June 9, 2011 Respectfully submitted, LOZEAU DRURY LLP 3 By: /s/ Douglas J. Chermak__ Douglas J. Chermak Attorneys for Plaintiff GLOBAL COMMUNITY MONITOR 5 6 9 S IT IS SO ORDERED. UNIT ED 8 RT U O 7 S DISTRICT TE C TA _______________________________ Judge Edward M. Chen D United StatesRDEREJudge O O District IT IS S 10 dwar Judge E 13 14 A H ER LI RT 12 en d M. Ch NO 11 R NIA 4 FO 2 N F D IS T IC T O R C 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REQUEST TO CONTIUNE CASE MANAGEMENT CONFERENCE 2 11-00976

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