San Francisco Baykeeper v. Taylor

Filing 6

ORDER GRANTING REQUEST TO CONTINUE CASE MANAGEMENT DEADLINES. Case Management Statement due by 4/28/2016. Case Management Conference set for 5/5/2016 10:00 AM. Signed by Judge Maria-Elena James on 2/24/2016. (cdnS, COURT STAFF) (Filed on 2/24/2016)

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George Torgun (Bar No. 222085)
Nicole C. Sasaki (Bar No. 298736)
SAN FRANCISCO BAYKEEPER
1736 Franklin Street, Suite 800
Oakland, California 94612
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiff
SAN FRANCISCO BAYKEEPER

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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SAN FRANCISCO BAYKEEPER, a non-profit
corporation,

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Plaintiff,

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v.
JAMES F. TAYLOR dba PINOLE RODEO
AUTO WRECKERS,

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Defendant.

Civil No. 4:15-cv-05825-MEJ
REQUEST TO CONTINUE CASE
MANAGEMENT CONFERENCE AND
ASSOCIATED DEADLINES; [PROPOSED]
ORDER
(Federal Water Pollution Control Act, 33
U.S.C. § 1251 et seq.)
Honorable Maria-Elena James

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REQUEST TO CONTINUE CMC -- Civil No. 4:15-cv-05825-MEJ

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WHEREAS, on December 18, 2015, Plaintiff San Francisco Baykeeper (“Plaintiff”) filed the
above-entitled action;
WHEREAS, Plaintiff’s deadline to serve the complaint on Defendant James F. Taylor
(“Defendant”) is March 17, 2016, pursuant to Fed. R. Civ. P. 4(m);
WHEREAS, on February 17, 2016, Plaintiff transmitted to Defendant a Request for Waiver of

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the Service of Summons, and is awaiting receipt of Defendant’s Executed Waiver of the Service of

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Summons;

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WHEREAS, Plaintiff and Defendant (collectively, the “Parties”) have been working together
in good faith to reach a settlement agreement in this action;

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WHEREAS, the Court’s Order Setting Initial Case Management Conference and ADR

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Deadlines (“Scheduling Order”) set the initial Case Management Conference in this matter for March

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17, 2016 at 10:00 a.m.;

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WHEREAS, the Scheduling Order states that if the Initial Case Management Conference is
continued, the other deadlines are continued accordingly;
WHEREAS, the Parties desire to continue informal negotiations in good faith, and anticipate
reaching a final settlement in this action within the next ten (10) weeks;
WHEREAS, Plaintiff requests, upon the Court’s approval, to reschedule the Case Management

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Conference for May 5, 2016, at 10:00 a.m., or at such later date that is convenient for the Court, in

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order to give the Parties a chance to complete settlement negotiations without involving the resources

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of the Court;

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WHEREAS, Plaintiff requests, upon the Court’s approval, to reschedule the deadline to file the

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Parties’ ADR certifications and stipulations to ADR process or notices of need for an ADR phone

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conference no later than one week before the Case Management Conference;

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WHEREAS, Plaintiff requests, upon the Court’s approval, to reschedule the deadline to file the

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Parties’ Rule 26(f) Report and Joint Case Management Statement no later than one week before the

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Case Management Conference;

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REQUEST TO CONTINUE CMC -- Civil No. 4:15-cv-05825-MEJ

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WHEREAS, Plaintiff requests, upon the Court’s approval, to reschedule the deadline to file the
Parties’ initial disclosures or objections in their Rule 26(f) Report no later than one week before the
Case Management Conference;
WHEREFORE, Plaintiff respectfully requests the Court to approve and enter the Proposed
Order below.
DATE: February 23, 2016

Respectfully Submitted,
/s/ Nicole C. Sasaki
Nicole C. Sasaki
Attorneys for Plaintiff
SAN FRANCISCO BAYKEEPER

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REQUEST TO CONTINUE CMC -- Civil No. 4:15-cv-05825-MEJ

[PROPOSED] ORDER

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GOOD CAUSE APPEARING,
May 5, 2016
1. The Case Management Conference shall be continued to ________________________
at 10:00 a.m.
2. The Parties’ ADR certifications and stipulations to ADR process or notices of need for

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an ADR phone conference shall be filed no later than one week before the Case

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Management Conference.

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3. The Parties’ Rule 26(f) Report and Joint Case Management Statement shall be filed no
later than one week before the Case Management Conference.
4. The Parties’ initial disclosures or objections in their Rule 26(f) Report shall be filed no
later than one week before the Case Management Conference.
IT IS SO ORDERED.

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February 24, 2016
Date: ____________________

NORTHERN DISTRICT OF CALIFORNIA

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_____________________________________
Honorable Maria-Elena James
United States District Court

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REQUEST TO CONTINUE CMC -- Civil No. 4:15-cv-05825-MEJ