Food & Water Watch, Inc. et al v. Environmental Protection Agency et al

Filing 40

STIPULATION AND ORDER re 39 briefing schedule on Motion for Protective Order and resetting CMC. Case Management Statement due by 1/18/2018. Initial Case Management Conference reset for 1/25/2018 01:30 PM in Courtroom 5, 17th Floor, San Francisco. Motion for Protective Order Hearing set for 1/25/2018 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Judge Edward M. Chen. Signed by Judge Edward M. Chen on 12/5/17. (bpfS, COURT STAFF) (Filed on 12/5/2017)

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MICHAEL CONNETT, ESQ., CA Bar No. 300314
CHRIS NIDEL, ESQ., D.C. Bar No. 497059
FOOD & WATER WATCH
1814 Franklin St., Suite 1100
Oakland, California 94612
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Plaintiffs

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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Case No.: 17-cv-02162-EMC

FOOD & WATER WATCH, INC, et al.,
Plaintiffs,
v.
U.S. Environmental Protection Agency,
et al.,

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Defendants.

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STIPULATION TO EXTEND DEADLINES FOR EPA’S MOTION FOR
PROTECTIVE ORDER BRIEFING SCHEDULE

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Plaintiffs Food & Water Watch, et al., and Defendants United States

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Environmental Protection Agency, et al., (“EPA”) hereby stipulate to and request that the

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Court enter the attached Order extending the deadlines associated with EPA’s motion for

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a protective order.

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1. Pursuant to the Court’s September 12, 2017 Order (ECF No. 27), EPA’s

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motion for a protective order is due 12/7/17, Plaintiffs’ response is due 12/21/17, EPA’s

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reply is due 1/4/18, and the hearing date is 1/18/18.

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CASE NO. 17-CV-02162-EMC

STIPULATION TO EXTEND DEADLINES FOR EPA’S MOTION FOR PROTECTIVE
ORDER BRIEFING SCHEDULE AND [PROPOSED] ORDER
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2. Due to scheduling conflicts with other current litigation, the parties have met

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and conferred on extending the aforementioned deadlines for the motion and reply by one

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week and for the response by 12 days. The parties have agreed to push the deadline for

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EPA’s motion back to 12/14/17, Plaintiffs’ response to 1/2/11, EPA’s reply to 1/11/18,

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and the hearing date to 1/25/18. The parties also agree that the dates for the further case

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management conference and updated joint case management conference statement also

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be extended by one week.

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3. This extension will not significantly delay resolution of the case.

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4. Accordingly, the parties jointly stipulate and request that the Court enter the

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attached order providing the following schedule:

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EPA’s Motion for a Protective Order – December 14, 2017

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Plaintiffs’ Response to Motion – January 2, 2017

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EPA’s Reply – January 11, 2018

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Updated Joint Case Management Conference Statement – January 18

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Hearing and Further Case Management Conference – January 25, 2018
Dated: December 5, 2017

Respectfully submitted,

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/s/ Michael Connett
MICHAEL CONNETT
CHRIS NIDEL
Food & Water Watch
1814 Franklin St., Suite 1100
Oakland, CA 94612
Tel: [phone]

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Attorneys for Plaintiffs

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JEFFREY H. WOOD
Acting Assistant Attorney General

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/s/ Norman L. Rave, Jr. (by
permission)

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CASE NO. 17-CV-02162-EMC

STIPULATION TO EXTEND DEADLINES FOR EPA’S MOTION FOR PROTECTIVE
ORDER BRIEFING SCHEDULE AND [PROPOSED] ORDER
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NORMAN L. RAVE, JR.
Environmental Defense Section
601 D Street, NW, Suite 8000
Washington, DC 20004
Tel: [phone]
Email: [e-mail]

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Attorneys for Defendants

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CASE NO. 17-CV-02162-EMC

STIPULATION TO EXTEND DEADLINES FOR EPA’S MOTION FOR PROTECTIVE
ORDER BRIEFING SCHEDULE AND [PROPOSED] ORDER
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[PROPOSED] ORDER
Before the Court is the parties’ Stipulation to Extend the Deadlines for EPA’s

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Motion for a Protective Order Briefing Schedule And [Proposed] Order.. Upon due

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consideration, and for good cause shown, the parties’ request is hereby GRANTED. It is

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further ordered that the following schedule will govern Defendants’ Motion for a

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Protective Order and Plaintiffs’ response thereto:

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EPA’s Motion for a Protective Order – December 14, 2017

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Plaintiffs’ Response to Motion – January 2, 2017

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EPA’s Reply – January 11, 2018

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5th
December
DATED this ______ day of ________________, 2017.

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S

O
IT IS S
DIFIED
AS MO
ard M.

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Judge E

ER

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RT

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EDWARD M. CHEN
United States ORDERED Judge
District Court

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UNIT
ED

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RT
U
O

S DISTRICT
TE
C
TA
________________________________

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R NIA

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PURSUANT TO STIPULATION IT IS SO ORDERED.

Chen

FO

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Hearing and Further Case Management Conference – January 25, 2018 (1:30 pm)

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Updated Joint Case Management Conference Statement – January 18

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N

F
D IS T IC T O
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CASE NO. 17-CV-02162-EMC

STIPULATION TO EXTEND DEADLINES FOR EPA’S MOTION FOR PROTECTIVE
ORDER BRIEFING SCHEDULE AND [PROPOSED] ORDER
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CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served by Notice
of Electronic Filing this 5th day of December, 2017, upon all ECF registered counsel of
record using the Court’s CM/ECF system.

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/s/ Michael Connett
MICHAEL CONNETT
Attorney for Plaintiffs

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CASE NO. 17-CV-02162-EMC

STIPULATION TO EXTEND DEADLINES FOR EPA’S MOTION FOR PROTECTIVE
ORDER BRIEFING SCHEDULE AND [PROPOSED] ORDER
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