California Sportfishing Protection Alliance v. Georgia-Pacific Gypsum LLC et al

Filing 13

ORDER : Initial Case Management Conference set for 3/15/13 is continued to 4/19/2013 02:30 PM in Courtroom 10, 19th Floor, San Francisco.. Signed by Judge Susan Illston on 3/6/13., Motions terminated: 12 STIPULATION WITH PROPOSED ORDER To Continue Case Management Schedule filed by California Sportfishing Protection Alliance. (tfS, COURT STAFF) (Filed on 3/7/2013)

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ANDREW L. PACKARD (State Bar No. 168690)
EMILY J. BRAND (State Bar No. 267564)

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Law Offices of Andrew L. Packard
100 Petaluma Blvd. N. Ste. 301
Petaluma, CA 94952
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
[e-mail]

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Attorneys for Plaintiff California Sportfishing Protection Alliance

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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CALIFORNIA SPORTFISHING
PROTECTION ALLIANCE, a non-profit
corporation;

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Case No. 3:12-CV-06274-SI

Plaintiff,
vs.
GEORGIA-PACIFIC GYPSUM LLC, a
Delaware limited liability company;
GEORGIA-PACIFIC BUILDING
PRODUCTS LLC, a Delaware limited
liability company; RICK TURNER, an

STIPULATION TO CONTINUE CASE
MANAGEMENT SCHEDULE;
DECLARATION OF EMILY BRAND;
[PROPOSED] ORDER [Civil L.R. 16-2(d)]

individual; MANOJ MATHUR, an
individual; ROBERT CYPHERS, an
individual; JEREMIAH DAVIS, an
individual; MICHAEL WOODY, an
individual; FRED CURCIO, an
individual,
Defendants.

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together with

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Defendants Georgia-Pacific Gypsum LLC, Georgia-Pacific Building Products LLC,
Robert Cyphers, Jeremiah Davis, Michael Woody, Fred Curcio, Rick Turner and

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Manoj Mathur hereby stipulate and move to continue the remaining case

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management schedule dates set in the Order dated December 11, 2012 (Court Doc

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#3) and amended by the Case Management Conference Order (Court Doc #8) to be

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Stipulation for Relief from Case Management Schedule

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Case No. 3:12-CV-06274-SI

continued by a period of thirty (30) days.
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Date: February 28, 2013

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LAW OFFICES OF ANDREW L. PACKARD
/s/ Emily J. Brand______________________
Emily J. Brand
Attorneys for Plaintiff
California Sportfishing Protection Alliance

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Date: February 28, 2013

COX CASTLE & NICHOLSON LLP
/s/_Robert P. Doty__________________
Robert P. Doty
Attorneys for Defendants
Georgia-Pacific Gypsum LLC, et al.

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Stipulation for Relief from Case Management Schedule

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Case No. 3:12-CV-06274-SI

DECLARATION OF EMILY BRAND
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1. I am an attorney for Plaintiff California Sportfishing Protection Alliance, herein.
2. This action is a complaint for declaratory and injunctive relief and civil penalties brought
against Defendants Georgia-Pacific Gypsum LLC, Georgia-Pacific Building Products LLC,
Robert Cyphers, Jeremiah Davis, Michael Woody, Fred Curcio, Rick Turner and Manoj
Mathur

for current and ongoing violations of the Clean Water Act, 33

U.S.C. § 1251 to § 1387. The action was filed on December 11, 2012.
3. Plaintiff has not served Defendants at this time.
4. The parties are in active negotiations to settle the matter and hope to reach a complete
resolution of this matter soon. Plaintiff has presented Defendants with a settlement
proposal and Defendants have provided substantive comments on this agreement.
5. The parties agree that it is in their mutual best interests to request a short continuation of all
Court deadlines to allow the parties to continue the settlement negotiations.
6. I am therefore requesting all current deadlines be extended thirty days, to allow Plaintiff
and Defendants to come to a settlement agreement.

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I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct and that this declaration was executed in Berkeley, CA on February 28, 2013.

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Dated: 2/28/2013

Law Offices of Andrew L. Packard

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By:

__/s/ Emily J. Brand_________________________
Emily J. Brand
Attorneys for Plaintiff

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Stipulation; Declaration; [PROPOSED] Order

Case No. 3:12-CV-06274-SI

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[PROPOSED ORDER]

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GOOD CAUSE APPEARING, it is hereby, ORDERED, that the deadlines set forth in the
Notice Setting Case Management Conference be extended as follows:

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Last day to file Rule 26(f) Report, complete initial disclosures or state
Objection and file Case Management Statement

- April 5, 2013

Initial Case Management Conference

- April 15, 2013

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3/6/13
Dated: __________________

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_________________________________________
UNITED STATES DISTRICT JUDGE

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Stipulation; Declaration; [PROPOSED] Order

Case No. 3:12-CV-06274-SI