United States of America v. California Department of Transportation

Filing 82

STIPULATION AND ORDER REQUESTING STAY AS A RESULT OF PARTIES REACHING AGREEMENT IN PRINCIPLE re 81 Stipulation filed by United States of America. Signed by Judge Phyllis J. Hamilton on 3/2/11. (nah, COURT STAFF) (Filed on 3/2/2011)

United States of America v. California Department of Transportation

Doc. 82

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BRADLEY R. O'BRIEN DAVIS H. FORSYTHE Trial Attorneys Environmental Enforcement Section Environment and Natural Resources Division United States Department of Justice 601 D. Street, N.W. Washington, D.C. 20004 Tel.:[phone] Fax:[phone] MA Bar No.: 667115 Email: [e-mail] [e-mail] Attorneys for Plaintiff the United States

10 11 12 13 14 15 Plaintiff, 16 17 18 19 20 21 22 23 24 25 26 27 28 "Caltrans") 1. The United States and the California Department of Transportation( (jointly "Parties")have reached an agreement in principle that would resolve the instant litigation. 2. To allow the parties to draft a final agreement and to obtain approval of appropriate officials of the United States Department of Justice, the Presidio Trust, the United States Army,the California Department of Transportation, and the California Transportation Commission, the parties respectfully request a 120 day stay of this matter. 1 Stipulation Requesting Stay as a Result ofParties Reaching Agreement in Princi~
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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION

THE UNITED STATES OF AMERICA,

Civil Action No. 4-09-CV-00437-PJH STIPULATED AGREEMENT AND [PROPOSED]ORDER REQUESTING STAY AS A RESULT OF PARTIES REACHING AGREEMENT IN PRINCIPLE

v.

THE CALIFORNIA DEPARTMENT OF TRANSPORTATION, Defendant.

Dockets.Justia.com

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3. The Parties hereby consent to entry of the foregoing Stipulation. Respectfully submitted, FOR PLAINTIFF THE UNITED STATES OF AMERICA: Date. / ' ~/~...~ Bradley R. O'Brien Davis H. Forsythe Trial Attorneys Environmental Enforcement Section Environment and Natural Resources Division United States Department of Justice 601 D Street, N.W. Washington, D.C. 20004

FOR DEFENDANT THE CALIFORNIA DEPARTMENT OF TRANSPORTATION:

Date: ~ ~ It Jan t Wong ~~~ D uty Attorney California Department of Transportation 595 Market Street, Suite 1700 San Francisco, CA 94105

PURSUANT TO STIPULATION,IT IS SO ORDERED.
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