California Sportfishing Protection Alliance v. Criterion Catalysts & Technologies LP

Filing 13

ORDER granting 12 Stipulation to Extend Deadline for Repsonsive Pleading and Reschedule Case Management Conference filed by California Sportfishing Protection Alliance. Joint Case Management Statement due by 11/25/2013. Initial Case Management Conference reset for 12/5/2013 01:30 PM in Courtroom F, 15th Floor, San Francisco. Signed by Magistrate Judge Jacqueline Scott Corley on 9/20/2013. (ahm, COURT STAFF) (Filed on 9/20/2013)

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Michael R. Lozeau (State Bar No. 142893)
Richard T. Drury (State Bar No. 163559)
Douglas J. Chermak (State Bar No. 233382)
LOZEAU DRURY LLP
410 12th Street, Suite 250
Tel: [phone]
Fax: [phone] (fax)
E-mail: [e-mail]
[e-mail]
Attorneys for Plaintiff
CALIFORNIA SPORTFISHING
PROTECTION ALLIANCE

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
CALIFORNIA SPORTFISHING
PROTECTION ALLIANCE, a non-profit
corporation,

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Plaintiff,
vs.

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CRITERION CATALYSTS &
TECHNOLOGIES, L.P., a corporation,

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Defendant.

Case No. 3:13-cv-01260-JSC
STIPULATION AND [PROPOSED] ORDER
TO EXTEND DEADLINE FOR
RESPONSIVE PLEADING AND
RESCHEDULE CASE MANAGEMENT
CONFERENCE
Judge: Hon. Jacqueline S. Corley
Proposed Responsive Pleading:
Proposed CMC:

Nov. 15, 2013
Dec. 5, 2013

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WHEREAS, on June 12, 2013, Plaintiff California Sportfishing Protection Alliance

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(“CSPA”) and Defendant Criterion Catalysts & Technologies, L.P. (“Criterion”) (collectively,

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“Parties”) first entered into a stipulation acknowledging that the deadline for Criterion to file a

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responsive pleading was extended to August 6, 2013 and requesting that the initial Case

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Management Conference be rescheduled to August 22, 2013 (“June 12 Stipulation”) (ECF Dkt. 7),

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to permit the Parties to engage in confidential settlement discussions that would resolve this matter

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outside of litigation. On June 12, 2013, the Court entered an order approving the June 12 Stipulation

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(ECF Dkt. 8).

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WHEREAS, on July 26, 2013, the Parties entered into a second stipulation requesting that

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the deadline for Criterion to file a responsive pleading be further extended to October 1, 2013 and

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requesting that the initial Case Management Conference be rescheduled to October 17, 2013 (“July
STIPULATION TO EXTEND DEADLINE FOR RESPONSIVE;
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PLEADING AND RESCHEDULE CMC;
[PROPOSED} ORDER

3:13-cv-01260-JSC

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26 Stipulation”) (ECF Dkt.10), to permit the Parties to continue to engage in confidential settlement

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discussions that would resolve this matter outside of litigation. On July 29, 2013, the Court entered

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an order approving the July 26 Stipulation (ECF Dkt. 11).
WHEREAS, since the June 12 Stipulation and the July 26 Stipulation, the Parties have been

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diligently engaged in confidential settlement discussions, which are still continuing and require

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additional time for the Parties to fully pursue, and are in the process of evaluating proposed

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settlement terms.
WHEREAS, the Parties believe that further short continuances of the deadline for Criterion’s

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responsive pleading and the initial Case Management Conference are necessary for the Parties to

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continue focusing on these discussions, to avoid diverting resources away from these discussions

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towards premature litigation, and to prevent the unnecessary expenditure of Court resources at this

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stage.

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WHEREAS, the Parties have agreed, upon the Court’s approval, to extend the time within

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which Criterion shall respond to the Complaint from October 1, 2013 to November 15, 2013, and to

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reschedule the Case Management Conference from October 17, 2013 to December 5, 2013.

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WHEREAS, no Parties would be prejudiced by the proposed continuances.

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THEREFORE, IT IS STIPULATED by and between the Parties, through their respective

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counsel, as follows:
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1, 2013 to November 15, 2013.

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2.

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The deadline to file the Joint Case Management Statement shall be extended from
October 10, 2013 to November 25, 2013.

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Criterion’s deadline for responding to the Complaint shall be extended from October

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The Case Management Conference shall be continued from 1:30 p.m. on October 17,
2013 to 1:30 p.m. on December 5, 2013.

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Dated: September 19, 2013

By: _/s/ Douglas J. Chermak______________
Douglas J. Chermak
Attorneys for Plaintiff
CALIFORNIA SPORTFISHING PROTECTION
ALLIANCE

STIPULATION TO EXTEND DEADLINE FOR RESPONSIVE;
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PLEADING AND RESCHEDULE CMC;
[PROPOSED} ORDER

3:13-cv-01260-JSC

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Dated: September 19, 2013

By: _/s/ Albert Giang (as authorized on 9/19/2013)
Albert Giang
Attorneys for Defendant
CRITERION CATALYSTS & TECHNOLOGIES, L.P.

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STIPULATION TO EXTEND DEADLINE FOR RESPONSIVE;
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PLEADING AND RESCHEDULE CMC;
[PROPOSED} ORDER

3:13-cv-01260-JSC

[PROPOSED] ORDER

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Based on the foregoing stipulation, IT IS HEREBY ORDERED, ADJUDGED, and DECREED that:
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1, 2013 to November 15, 2013.

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5.

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The deadline to file the Joint Case Management Statement shall be extended from
October 10, 2013 to November 25, 2013.

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Criterion’s deadline for responding to the Complaint shall be extended from October

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The Case Management Conference shall be continued from 1:30 p.m. on October 17,
2013 to 1:30 p.m. on December 5, 2013.

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IT IS SO ORDERED.

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NORTHERN DISTRICT COURT OF CALIFORNIA

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September 20, 2013
Dated: __________________

__________________________________________
The Honorable Jacqueline S. Corley
United States Magistrate Judge

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STIPULATION TO EXTEND DEADLINE FOR RESPONSIVE;
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PLEADING AND RESCHEDULE CMC;
[PROPOSED} ORDER

3:13-cv-01260-JSC