California Sportfishing Protection Alliance et al v. M & M Services, Inc.

Filing 29

STIPULATION AND ORDER to Extend Time for Defendant Shiloh Road, LLC to respond to the First Amended Complaint. Signed by Judge Thelton E. Henderson on 05/04/2012. (tmi, COURT STAFF) (Filed on 5/4/2012)

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ROGERS JOSEPH O’DONNELL
Robert C. Goodman (State Bar No. 111554)
[e-mail]
D. Kevin Shipp (State Bar No. 245947)
[e-mail]
311 California Street
San Francisco, California 94104
Telephone: [phone]
Facsimile: 415.956.6457
Attorneys for Defendant
SHILOH ROAD, LLC

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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CALIFORNIA SPORTFISHING
PROTECTION ALLIANCE, et al.,

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Plaintiffs,
vs.

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M & M SERVICES, INC., et al.,

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Defendants.

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Case No. C 11-02949 TEH
STIPULATION TO EXTEND TIME
WITHIN WHICH DEFENDANT
SHILOH ROAD, LLC IS TO RESPOND
TO THE FIRST AMENDED
COMPLAINT
First Amended Complaint Filed: December
6, 2011
Honorable Thelton E. Henderson

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IT IS HEREBY STIPULATED pursuant to Local Rule 6-1(a), by Plaintiffs and
Defendant Shiloh Road, LLC, by and through their undersigned counsel, as follows:
WHEREAS at the April 26, 2012 mediation session with Steven Weissman the
parties reached a tentative agreement to settle the action.
WHEREAS the parties are in the process of addressing one remaining technical
issue and drafting a formal settlement agreement.
WHEREAS, upon its finalization and execution, the agreement between

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Plaintiffs and Defendant M & M Services, Inc. will be submitted to the United States

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Environmental Protection Agency and United States Department of Justice for consideration

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by those agencies during a forty-five (45) day review period.
Page 1
Stipulation to Extend Time Within Which Defendant Shiloh Road, LLC is to Respond to First Amended Complaint
CASE NO: C 11-02949 TEH
316991.4

WHEREAS Defendant Shiloh Road, LLC’s response to the First Amended

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Complaint is currently due May 14, 2012, and the parties wish to avoid the expense of

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responding to the First Amended Complaint in light of the likely settlement.

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WHEREAS Plaintiffs and Shiloh Road, LLC have agreed that Shiloh Road,

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LLC may have an additional ninety (90) days to respond to the First Amended Complaint.
WHEREAS the stipulation to extend the time within which Shiloh, LLC is to

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answer or otherwise respond to the First Amended Complaint will not alter the date of any

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event or any deadline already fixed by Court order.
NOW THEREFORE, Plaintiffs and Shiloh Road, LLC, by and through their

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undersigned counsel, hereby stipulate and agree that, the time within which Shiloh Road,

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LLC is to answer or otherwise respond to Plaintiffs’ First Amended Complaint is extended to

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and including August 14, 2012.

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Dated: May 3, 2012

LOZEAU DRURY LLP

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By:

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/s/ Michael R. Lozeau
MICHAEL R. LOZEAU
Attorneys for Plaintiffs California
Sportfishing Protection Alliance and
Petaluma River Council

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ROGERS JOSEPH O'DONNELL

Dated: May 3, 2012

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By:

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/s/ Robert C. Goodman
ROBERT C. GOODMAN
Attorneys for Defendant
SHILOH ROAD, LLC

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Lozeau for Plaintiffs.
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lton E. H

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Judge T

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UNIT
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05/04/2012

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ISTRIC
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By:

/s/ Robert C. Goodman
ROBERT C. GOODMAN
Attorneys for Defendant
SHILOH ROAD, LLC
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LI

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I attest that concurrence in the filing of this document has been obtained from Michael

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Stipulation to Extend Time Within Which Defendant Shiloh Road, LLC is to Respond to First Amended Complaint
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CASE NO: R N
C 11-02949 TEH F C
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D IS T IC T O
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316991.4