San Francisco Baykeeper v. Granite Rock Company
Filing
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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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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
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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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SAN FRANCISCO BAYKEEPER, a non-profit
corporation,
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Plaintiff,
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v.
GRANITE ROCK COMPANY, a California
corporation,
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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
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Second Stipulation to Continue CMC
Civil No. 4:16-cv-01089-KAW
Plaintiff San Francisco Baykeeper (“Baykeeper” or “Plaintiff”) and Defendant Granite Rock
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Company (“Granite Rock” or “Defendant”) respectfully submit this stipulation as follows:
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WHEREAS, Baykeeper and Granite Rock (collectively, the “Parties”) have been working
together in good faith to reach a settlement agreement in this action;
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WHEREAS, pursuant to a stipulation by the Parties (Dkt. 10), the Court set the initial Case
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Management Conference in this matter for September 27, 2016 at 1:30 p.m., and continued other
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deadlines in the case (Dkt. 12);
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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.
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NOW, THEREFORE, THE PARTIES STIPULATE AS FOLLOWS:
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1. The Case Management Conference shall be continued to October 11, 2016, at 1:30
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p.m., or at such later date that is convenient for the Court, in order to give the Parties a
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chance to complete settlement negotiations without involving the resources of the
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Court.
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2. The Parties’ ADR certifications and stipulations to ADR process or notices of need for
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an ADR phone conference shall be due no later than one week before the Case
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Management Conference.
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3. The Parties’ Rule 26(f) Report and Joint Case Management Statement shall be due no
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later than one week before the Case Management Conference.
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4. The Parties’ initial disclosures or objections in their Rule 26(f) Report shall be due no
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later than one week before the Case Management Conference.
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Second Stipulation to Continue CMC
Civil No. 4:16-cv-01089-KAW
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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
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NICOLE C. SASAKI
Attorney for Plaintiff
SAN FRANCISCO BAYKEEPER
GRANITE ROCK COMPANY
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DATE: September 14, 2016
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By:
/s/ Gregory O’Hara
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GREGORY O’HARA
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Attorney for Defendant
GRANITE ROCK COMPANY
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I attest that concurrence in the filing of this document has been obtained from Gregory O’Hara
for Granite Rock.
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DATE: September 14, 2016
SAN FRANCISCO BAYKEEPER
By:
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/s/ Nicole C. Sasaki
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NICOLE C. SASAKI
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Attorney for Plaintiff
SAN FRANCISCO BAYKEEPER
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Second Stipulation to Continue CMC
Civil No. 4:16-cv-01089-KAW
[PROPOSED] ORDER
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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
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an ADR phone conference shall be filed no later than one week before the Case
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Management Conference.
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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.
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9/20/16
Date: ____________________
NORTHERN DISTRICT OF CALIFORNIA
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_____________________________________
Honorable Kandis A. Westmore
United States District Court
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Second Stipulation to Continue CMC
Civil No. 4:16-cv-01089-KAW
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