San Francisco Baykeeper v. Granite Rock Company

Filing 19

STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE 17 . Signed by Magistrate Judge Kandis A. Westmore on 9/20/16. (sis, COURT STAFF) (Filed on 9/20/2016)

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1 2 3 4 5 6 7 Erica A. Maharg (Bar No. 279396) Nicole C. Sasaki (Bar No. 298736) SAN FRANCISCO BAYKEEPER 1736 Franklin Street, Suite 800 Oakland, California 94612 Telephone: (510) 735-9700 Facsimile: (510) 735-9160 Email: erica@baykeeper.org Email: nicole@baykeeper.org Attorneys for Plaintiff SAN FRANCISCO BAYKEEPER 8 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 OAKLAND DIVISION 12 13 14 SAN FRANCISCO BAYKEEPER, a non-profit corporation, 15 Plaintiff, 16 17 18 v. GRANITE ROCK COMPANY, a California corporation, 19 20 Defendant. Civil No. 4:16-cv-01089-KAW SECOND STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES; [PROPOSED] ORDER (Federal Water Pollution Control Act, 33 U.S.C. § 1251 et seq.) Honorable Kandis A. Westmore 21 22 23 24 25 26 27 28 Second Stipulation to Continue CMC Civil No. 4:16-cv-01089-KAW Plaintiff San Francisco Baykeeper (“Baykeeper” or “Plaintiff”) and Defendant Granite Rock 1 2 Company (“Granite Rock” or “Defendant”) respectfully submit this stipulation as follows: 3 4 WHEREAS, Baykeeper and Granite Rock (collectively, the “Parties”) have been working together in good faith to reach a settlement agreement in this action; 5 WHEREAS, pursuant to a stipulation by the Parties (Dkt. 10), the Court set the initial Case 6 Management Conference in this matter for September 27, 2016 at 1:30 p.m., and continued other 7 deadlines in the case (Dkt. 12); 8 9 WHEREAS, the Parties desire to continue informal negotiations in good faith, and anticipate reaching a final settlement in this action within the next four (4) weeks. 10 NOW, THEREFORE, THE PARTIES STIPULATE AS FOLLOWS: 11 1. The Case Management Conference shall be continued to October 11, 2016, at 1:30 12 p.m., or at such later date that is convenient for the Court, in order to give the Parties a 13 chance to complete settlement negotiations without involving the resources of the 14 Court. 15 2. The Parties’ ADR certifications and stipulations to ADR process or notices of need for 16 an ADR phone conference shall be due no later than one week before the Case 17 Management Conference. 18 3. The Parties’ Rule 26(f) Report and Joint Case Management Statement shall be due no 19 later than one week before the Case Management Conference. 20 4. The Parties’ initial disclosures or objections in their Rule 26(f) Report shall be due no 21 22 23 24 later than one week before the Case Management Conference. /// /// /// 25 /// 26 /// 27 28 Second Stipulation to Continue CMC Civil No. 4:16-cv-01089-KAW 1 2 3 WHEREFORE, the Parties respectfully request the Court to approve and enter the Proposed Order below. DATE: September 14, 2016 Respectfully Submitted, /s/ Nicole C. Sasaki 4 NICOLE C. SASAKI Attorney for Plaintiff SAN FRANCISCO BAYKEEPER GRANITE ROCK COMPANY 5 6 DATE: September 14, 2016 7 By: /s/ Gregory O’Hara 8 GREGORY O’HARA 9 Attorney for Defendant GRANITE ROCK COMPANY 10 11 12 13 I attest that concurrence in the filing of this document has been obtained from Gregory O’Hara for Granite Rock. 14 15 DATE: September 14, 2016 SAN FRANCISCO BAYKEEPER By: 16 /s/ Nicole C. Sasaki 17 NICOLE C. SASAKI 18 Attorney for Plaintiff SAN FRANCISCO BAYKEEPER 19 20 21 22 23 24 25 26 27 28 Second Stipulation to Continue CMC Civil No. 4:16-cv-01089-KAW [PROPOSED] ORDER 1 2 3 4 5 GOOD CAUSE APPEARING, 10/25/16 1. The Case Management Conference shall be continued to ________________________ at 1:30 p.m. 2. The Parties’ ADR certifications and stipulations to ADR process or notices of need for 6 an ADR phone conference shall be filed no later than one week before the Case 7 Management Conference. 8 9 10 11 12 3. The Parties’ Rule 26(f) Report and Joint Case Management Statement shall be filed no later than one week before the Case Management Conference. 4. The Parties’ initial disclosures or objections in their Rule 26(f) Report shall be filed no later than one week before the Case Management Conference. IT IS SO ORDERED. 13 14 9/20/16 Date: ____________________ NORTHERN DISTRICT OF CALIFORNIA 15 16 _____________________________________ Honorable Kandis A. Westmore United States District Court 17 18 19 20 21 22 23 24 25 26 27 28 Second Stipulation to Continue CMC Civil No. 4:16-cv-01089-KAW

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