Northern California River Watch v. Chevron U.S.A. Inc. et al

Filing 27

ORDER re 26 GRANTING Third Joint Stipulation to Continue Initial Disclosure and Case Management Conference Dates; Second Joint Stipulation for Extension of Deadline for Conducting Private ADR. Initial Case Management Conference set for 12/15/2009 02:00 PM.. Signed by Judge CLAUDIA WILKEN on 11/5/09. (scc, COURT STAFF) (Filed on 11/5/2009)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

ROGERS JOSEPH O'DONNELL ROBERT C. GOODMAN (State Bar No. 111554) [e-mail] ANN M. BLESSING (State Bar No. 172573) [e-mail] D. KEVIN SHIPP (State Bar No. 245947) [e-mail] 311 California Street San Francisco, California 94104 Telephone: [phone] Facsimile: 415.956.6457 Attorneys for Defendants CHEVRON U.S.A. INC. and CHEVRON CORPORATION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA NORTHERN CALIFORNIA RIVER WATCH, a non-profit corporation, Plaintiff, vs. CHEVRON U.S.A. INC., CHEVRON CORPORATION, and DOES 1-10, Inclusive, Defendants. Case No. 4:09-cv-00669-CW THIRD JOINT STIPULATION AND ORDER TO CONTINUE INITIAL DISCLOSURE AND CASE MANAGEMENT CONFERENCE DATES; SECOND JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF DEADLINE FOR CONDUCTING PRIVATE ADR; DECLARATION OF ROBERT C. GOODMAN IN SUPPORT THEREOF

DECLARATION OF ROBERT C. GOODMAN 1. I am a shareholder at the law firm of Rogers Joseph O'Donnell,

attorneys for Defendants Chevron U.S.A. Inc. and Chevron Corporation. I know the following facts on my own personal knowledge and if called upon could and would competently testify thereto. 2. This action was filed on February 13, 2009 and Defendants answered

the complaint on May 7, 2009. A Case Management Conference ("CMC") was originally set
Page 1 JOINT STIPULATION AND [PROPOSED] ORDER CASE NO: 4:09-cv-00669-CW
284501.1

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

for June 23, 2009. 3. On June 3, 2009, Counsel for the parties submitted a Joint Stipulation

and [Proposed] Order to Continue Initial Disclosure and Case Management Conference Dates. The Court signed the Order on June 10, 2009, continuing the Case Management Conference to August 25, 2009, at 2:00 p.m., and setting the last date for completing initial disclosures to August 18, 2009. 4. On August 14, 2009, Counsel for the parties submitted a Second Joint

Stipulation and [Proposed] Order to Continue Initial Disclosure and Case Management Conference Dates. The Court signed the Order on August 14, 2009, continuing the Case Management Conference to November 17, 2009 at 2:00 p.m., and setting the last for completing initial disclosures to October 27, 2009. 5. On June 2, 2009, Counsel for the parties submitted a Stipulation and

[Proposed] Order Selecting ADR Process. The Court signed the Order on June 4, 2009, setting the deadline for completing a Private ADR session for October 5, 2009. 6. On September 10, 2009, Counsel for the parties submitted a Stipulation

for Extension of Deadline for Conducting Mediation [Proposed] Order. The Court signed the Order on September 15, 2009, setting the deadline for completing a Private ADR session for November 11, 2009. 7. The parties immediately thereafter scheduled a Private ADR session

with William L. Nagle for November 11, 2009 at 9:30 a.m., the earliest date on which the mediator and all parties were available. Due to scheduling issues, it is not possible to commence mediation on November 11, and the parties, and mediator, have agreed to delay the mediation by one (1) week, and commence mediation on November 18, 2009. 8. The parties believe an additional brief continuance of the Case

Management Conference, and the other deadlines tied to the Case Management Conference date, is appropriate so that the parties can focus their attention on resolving this matter.

Page 2 JOINT STIPULATION AND [PROPOSED] ORDER CASE NO: 4:09-cv-00669-CW
284501.1

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

I declare under penalty of perjury that the foregoing is true and correct. Executed this 4th day of November 2009 in San Francisco, California. /s/ Robert C. Goodman Robert C. Goodman IT IS HEREBY STIPULATED by and between counsel for plaintiff and defendants as follows: (a) That the Case Management Conference scheduled for November 17,

2009 be continued to December 15, 2009 at 2:00 p.m.; (b) That the last day to complete initial disclosures and file a CMC

statement be continued to December 8, 2009; and (c) November 18, 2009. Dated: November 4, 2009 ROGERS JOSEPH O'DONNELL That the deadline for completing a Private ADR session be extended to

By:

/s/ Robert C. Goodman ROBERT C. GOODMAN

Attorneys for Defendants CHEVRON U.S.A. INC. and CHEVRON CORPORATION Dated: November 4, 2009 LAW OFFICE OF JACK SILVER

By:

/s/ Jack Silver JACK SILVER

Attorneys for Plaintiff NORTHERN CALIFORNIA RIVER WATCH PURSUANT TO STIPULATION IT IS HEREBY ORDERED: (a) That the Case Management Conference scheduled for November 17,

2009 be continued to December 15, 2009 at 2:00 p.m.; (b) That the last day to complete initial disclosures and file a CMC

statement be continued to December 8, 2009; and
Page 3 JOINT STIPULATION AND [PROPOSED] ORDER CASE NO: 4:09-cv-00669-CW
284501.1

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

(c) November 18, 2009.

That the deadline for completing a Private ADR session be extended to

Dated: November _5_, 2009

HONORABLE CLAUDIA WILKEN United States District Court Judge

Page 4 JOINT STIPULATION AND [PROPOSED] ORDER CASE NO: 4:09-cv-00669-CW
284501.1