California River Watch v. Lunny Grading & Paving, Inc. et al

Filing 29

STIPULATION AND ORDER re 28 STIPULATION WITH PROPOSED ORDER Joint Stipulation and Request for Extension of Deadline for Conducting ENE filed by California River Watch. Signed by Judge Jon S. Tigar on January 3, 2014. (wsn, COURT STAFF) (Filed on 1/3/2014)

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Jack Silver, Esq. SB #160575
Law Office of Jack Silver
Jerry Bernhaut, Esq. SB # 206264
Post Office Box 5469
Santa Rosa, CA 95402-5469
Tel. [phone]
Fax.[phone]
Email: [e-mail]

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Attorneys for Plaintiff
CALIFORNIA RIVER WATCH
S. Wayne Rosenbaum (SB #182456)
Ryan R. Waterman (SB #229485)
Juliet H. Cho (SB #271437)
STOEL RIVES LLP
12255 El Camino Real, Ste. 100
San Diego, CA 92130
Tel. [phone]
Fax. [phone]
Email: [e-mail]; [e-mail]; [e-mail]
Attorneys for Defendant
LUNNY GRADING & PAVING, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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CALIFORNIA RIVER WATCH,
a
501(c)(3), nonprofit, public benefit
Corporation,

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Plaintiff,
v.

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JOINT STIPULATION AND REQUEST
FOR EXTENSION OF DEADLINE FOR
CONDUCTING ENE; [PROPOSED]
ORDER
[Civil L.R. 7-12; ADR L.R. 5-5(1)(a)]

LUNNY GRADING & PAVING, INC.;
DOES 1-10, Inclusive,

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CASE NO.: 3:13-cv-03174 JST

Defendants.

Case Mgmt Conf. Date: Feb. 26, 2014
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WHEREAS, pursuant to ADR Rule 5-5, the Parties to this action jointly and respectfully
move the Court for a two week extension of the deadline to conduct an ENE session;

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WHEREAS, the current deadline for conducting the ENE session in this matter is January

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16, 2014; and, the current deadline for requesting an extension of the ENE session in this matter

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is January 2, 2014;

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3:11-cv-03174 JST
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JOINT STIPULATION AND REQUEST FOR EXTENSION OF
DEADLINE FOR CONDUCTING ENE SESSION; [PROPOSED] ORDER

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WHEREAS the parties are actively participating in discussions with respect to resolution

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of the issues raised in the Complaint, and expect to resolve this matter by way of a written

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agreement within the next few weeks; and have so advised Evaluator Stephen Schrey;

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WHEREAS the parties believe that good cause exists for the Court to grant an extension

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of the current deadline for conducting the ENE session to allow the parties to complete their

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settlement discussions;

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NOW, THEREFORE, the Parties hereby request an extension of the current deadline for
conducting the ENE session from January 16, 2014 to January 31, 2014.

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Dated: January 2, 2014

LAW OFFICE OF JACK SILVER
/s/ Jack Silver

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By:
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JACK SILVER
Attorney for Plaintiff
CALIFORNIA RIVER WATCH

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Dated: January 2, 2014

STOEL RIVES LLP
/s/ Ryan R. Waterman

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By:
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RYAN R. WATERMAN
Attorney for Defendant
LUNNY GRADING & PAVING, INC.

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[PROPOSED] ORDER
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PURSUANT TO SAID STIPULATION, IT IS SO ORDERED.
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DATED: January 3, 2014
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____________________________________
JON S. TIGAR
UNITED STATES DISTRICT JUDGE

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3:11-cv-03174 JST
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JOINT STIPULATION AND REQUEST FOR EXTENSION OF
DEADLINE FOR CONDUCTING ENE SESSION; [PROPOSED] ORDER