Gregory Village Partners, L.P. v. Chevron U.S.A., Inc. et al

Filing 45

STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE re 44 Proposed Order filed by Chevron U.S.A., Inc. Joint Case Management Statement due by 11/23/2011. Case Management Conference set for 12/1/2011 02:00 PM. Signed by Judge Phyllis J. Hamilton on 9/6/11. (nah, COURT STAFF) (Filed on 9/6/2011)

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ROGERS JOSEPH O’DONNELL
ROBERT C. GOODMAN (State Bar No. 111554)
ANN M. BLESSING (State Bar No. 172573)
D. KEVIN SHIPP (State Bar No. 245947)
311 California Street
San Francisco, California 94104
Tel
415.956.2828
Fax [phone]
[e-mail], [e-mail], [e-mail]

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Attorneys for Defendant CHEVRON U.S.A. INC.

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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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GREGORY VILLAGE PARTNERS, L.P.,

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Plaintiff,
vs.
CHEVRON U.S.A. INC., M.B.
ENTERPRISES, and CENTRAL CONTRA
COSTA SANITARY DISTRICT,

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Defendants.

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Case No. C 11-01597-PJH
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE;
DECLARATION OF ROBERT C.
GOODMAN IN SUPPORT THEREOF
First Amended Complaint Filed: August 24,
2011
Honorable Phyllis J. Hamilton

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DECLARATION OF ROBERT C. GOODMAN
1.

I am a shareholder with the law firm of Rogers Joseph O’Donnell,

attorneys for Defendant Chevron U.S.A. Inc. I have personal knowledge of the facts set forth
herein, and if called upon could and would competently testify thereto.
2.

Pursuant to this Court’s Order dated May 3, 2011, a case management

conference (“CMC”) was scheduled for July 21, 2011 in this matter.
3.

Pursuant to this Court’s Order dated July 1, 2011 (Document 24), the

CMC scheduled for July 21, 2011 was continued to September 22, 2011.

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Case No.: C 11-01597-PJH
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4.

Pursuant to this Court’s Order on August 2, 2011 (Document 40), the

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Court granted in part Defendants Chevron U.S.A. Inc., M. B. Enterprises, and Central Contra

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Costa Sanitary District motions to dismiss Plaintiff’s original Complaint and ordered Plaintiff

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to file an amended complaint no later than August 24, 2011.

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5.

In addition, the Court ordered the parties to submit a stipulation to

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continue the CMC if the pleadings will not be settled by the September 22, 2011 date

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presently set for the initial CMC.

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6.

Pursuant to this Court’s Order on August 2, 2011 (Document 40)

Plaintiff filed its First Amended Complaint on August 24, 2011 and Defendants’ responses to
the FAC must be filed no later than September 21, 2011.
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Defendants anticipate filing motions to dismiss the FAC, and thus the

pleadings will not be settled by September 22, 2011.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this 2nd day of September 2011 in San Francisco, California.

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/s/ Robert C. Goodman
Robert C. Goodman

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IT IS HEREBY STIPULATED pursuant to Local Rule 6-1(b) and Rule 6-2(a),
by the parties to this action, by and through their undersigned counsel, as follows:
A.

The case management conference currently set for September 22, 2011

shall be continued to December 1, 2011, or such other date as ordered by the Court.
B.

Any and all deadlines related to the case management conference shall

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be similarly continued.

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Dated: September 2, 2011

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STANZLER LAW GROUP
By:

/s/ Jordan S. Stanzler
JORDAN S. STANZLER
Attorney for Plaintiff
GREGORY VILLAGE PARTNERS, L.P.

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Case No.: C 11-01597-PJH
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Dated: September 2, 2011

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ROGERS JOSEPH O’DONNELL
By:

/s/ Robert C. Goodman
Robert C. Goodman
Attorney for Defendant
CHEVRON U.S.A. INC.

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Dated: September 2, 2011

SHAPIRO BUCHMAN PROVINE
BROTHERS SMITH LLP

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By:

/s/ Jack C. Provine
JACK C. PROVINE
Attorney for Defendant
MB ENTERPRISES, INC.

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Dated: September 2, 2011
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MEYERS, NAVE, RIBACK, SILVER &
WILSON

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By:
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/s/ Kenton L. Alm
KENTON L. ALM
Attorney for Defendant
CENTRAL CONTRA COSTA SANITARY
DISTRICT

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I attest that concurrence in the filing of this document has been obtained from Jordan S.

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Stanzler for Plaintiff, Jack C. Provine for Defendant MB Enterprises, Inc., and Kenton L.

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Alm for Defendant Central Contra Costa Sanitary District.

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By:

/s/ Robert C. Goodman
ROBERT C. GOODMAN
Attorney for Defendant
CHEVRON U.S.A. INC.

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ORDER

The case management conference is hereby continued to December 1, 2011, at 2:00
p.m. Any and all case management deadlines shall be calculated based on this new date.

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IT IS SO ORDERED.

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By ____________________________________
JUDGE PHYLLISDEHAMILTON
J. RED
SO OR DISTRICT JUDGE
UNITED STATES
IT IS

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yllis J.
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9/6/11
DATED: ______________________

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