California Sportfishing Protection Alliance v. Dapelo et al

Filing 31

STIPULATION AND ORDER re 30 TO RESET CMC filed by Richard Dapelo Case Management Statement due by 9/28/2017. Initial Case Management Conference set for 10/5/2017 09:30 AM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 8/15/17. (bpfS, COURT STAFF) (Filed on 8/15/2017)

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JAMES R. ARNOLD (SBN 56262)
JOHN A. BEARD (SBN 301405)
THE ARNOLD LAW PRACTICE (East Bay Office)
3685 Mt. Diablo Blvd., Suite 331
Lafayette, CA 94549
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Defendant
RICHARD DAPELO
dba QUALITY STAINLESS TANKS

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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CALIFORNIA SPORTFISHING
PROTECTION ALLIANCE, etc.,

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Plaintiff,

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Case No. 3:17-cv-00321-EMC
STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE AND
ASSOCIATED DEADLINES; AND

v.
[PROPOSED] ORDER

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RICHARD DAPELO, etc., et al.,
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Civil L.R. 6-2
Defendants.

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Plaintiff California Sportfishing Protection Alliance and Defendant Richard Dapelo

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respectfully submit this stipulation and proposed order as follows:
WHEREAS, Plaintiff and Defendant1 (collectively, the Parties) have been negotiating

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in good faith to attempt to reach a settlement in this action; and
WHEREAS, the Parties are in continuing settlement discussions and are working on

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the specific terms of a settlement; and
WHEREAS, the Court, at the Parties’ request, modified the Court’s schedule for this

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matter on March 23, 2017 (Docket No. 16), and May 9, 2017 (Docket No. 20) by rescheduling

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the dates for Defendant’s response to the complaint, the initial Case Management Conference,

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The Parties have filed their stipulation to dismiss putative defendant Quality Stainless Tanks. See Doc. No. 27,
filed Aug. 9, 2017.
Case No. 3:17-cv-00321-EMC
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE, ETC. AND [PROPOSED] ORDER - 1

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and associated deadlines; and

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WHEREAS, the Court, after Defendant’s declination of magistrate jurisdiction issued

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its Case Management Conference Order in Reassigned Case on July 12, 2017 (Docket No. 26),

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setting the initial Case Management Conference for August 24, 2017, with related dates as set

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by the Court, the Local Rules and the Federal Rules of Civil Procedure;

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WHEREAS, the Parties wish to attempt to conclude their settlement negotiations and
the specific terms of a settlement within the next thirty (30) days.

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NOW, THEREFORE, THE PARTIES STIPULATE AS FOLLOWS:
The Court is requested to:

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(a) Continue the Case Management Conference to October 5, 2017, or as soon
thereafter as may be convenient for the Court;

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(b) Continue all deadlines pursuant to Fed. R. Civ. P. 26 currently based on the August

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24, 2017 Case Management Conference date to the new date for the Case Management

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Conference.

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DATED: August 10, 2017

THE ARNOLD LAW PRACTICE

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By:

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/s/ James R. Arnold
JAMES R. ARNOLD
JOHN A. BEARD
Attorneys for Defendant
RICHARD DAPELO

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DATED: August 10, 2017

AQUA TERRA AERIS LAW GROUP LLP

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By:

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/s/ Anthony M. Barnes
ANTHONY M. BARNES
Attorneys for Plaintiff
CALIFORNIA SPORTFISHING
PROTECTION ALLIANCE

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Case No. 3:17-cv-00321-EMC
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE, ETC. AND [PROPOSED] ORDER - 2

ATTESTATION FOR E-FILING

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I hereby attest pursuant to Civil L.R. 5-1(i)(3) that I have obtained concurrence in the
filing of this document from the signatories prior to filing.

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DATED: August 10, 2017

By:

/s/ John A. Beard

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Case No. 3:17-cv-00321-EMC
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE, ETC. AND [PROPOSED] ORDER - 3

[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED. The Case Management Conference
shall be October 5, 2017, and the Case Management Statement due September 28, 2017. All

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related deadlines are reset accordingly.

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NO

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ERED

O ORD
______________________
IT IS S
EDWARD M. CHEN
United States District Judge
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M. Che
Edward
Judge
LI

8/15/17
DATED: ______________

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Case No. 3:17-cv-00321-EMC
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE, ETC. AND [PROPOSED] ORDER - 4