San Francisco Baykeeper v. Premier Recycle Company

Filing 24

STIPULATION AND ORDER continuing Case Management Conference to 10/29/2013 at 01:30 PM in Courtroom 2, 5th Floor, San Jose. Case Management Statement due by 10/22/2013. Signed by Judge Howard R. Lloyd on 9/23/13. (hrllc1, COURT STAFF) (Filed on 9/23/2013)

*E-Filed: September 23, 2013*
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Jayni Foley Hein (Bar No. 258261)
Andrea Kopecky (Bar No. 276366)
SAN FRANCISCO BAYKEEPER
785 Market Street, Suite 850
San Francisco, California 94103
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiff:
BAYKEEPER

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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SAN FRANCISCO BAYKEEPER, a non-profit
corporation,

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Plaintiff,
v.
PREMIER RECYCLE COMPANY,
Defendant.

Civil No. C 13-01695 HRL
STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE AND
ASSOCIATED DEADLINES; [PROPOSED]
ORDER
Fed. R. Civ. P. 26(f); L.R. 16-10
Honorable Howard R. Lloyd

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STIPULATION TO CONTINUE CASE MGMT CONFERENCE

Civil No. C 13-01695-HRL

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Plaintiff San Francisco Baykeeper (“Baykeeper”) and Defendant Premier Recycle Company
(“Premier Recycle”) in the above-captioned action respectfully submit this stipulation as follows:
WHEREAS, Baykeeper and Premier Recycle (collectively, the “Parties”) have been working
together in good faith to reach a settlement in this action;
WHEREAS, the Parties have already exchanged and are currently finalizing the terms of what
they anticipate will be a final Consent Decree for approval by the court;

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WHEREAS, the Court’s Order Setting Initial Case Management Conference and ADR

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Deadlines (“Scheduling Order”) set the initial Case Management Conference in this matter for July 23,

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2013 at 1:30 pm;

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WHEREAS, per a previous Stipulation and Order of the Court, the Initial Case Management
Conference was continued until August 20, 2013 at 1:30 p.m.;
WHEREAS, per a previous Stipulation and Order of the Court, the Initial Case Management
Conference was continued until September 10, 2013 at 1:30 p.m.;
WHEREAS, per a previous Stipulation and Order of the Court, the Initial Case Management
Conference was continued until October 1, 2013 at 1:30 p.m.;
WHERAS, the Parties submitted ADR certifications and stipulated to ADR process by
mediation on September 17, 2013;
WHEREAS, the Scheduling Order states that if the Initial Case Management Conference is
continued, the other deadlines are continued accordingly;
WHEREAS, the Parties desire to continue negotiating settlement in good faith and anticipate
reaching a final settlement in this action within the next two (2) weeks;
NOW, THEREFORE, THE PARTIES STIPULATE AS FOLLOWS:
1. The Case Management Conference shall be continued to October 22, 2013 at 1:30 pm, or
as soon thereafter as the Court is available.
2. The Parties’ Rule 26(f) Report and Joint Case Management Statement shall be due one
week before the Case Management Conference.
3. The Parties shall make initial disclosures or state objections in their Rule 26(f) Report no

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STIPULATION TO CONTINUE CASE MGMT CONFERNCE

Civil No. C 13-01695 HRL

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later than one week before the Case Management Conference.
Dated: September 20, 2013

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Respectfully submitted,

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By:
/s/ Andrea Kopecky
Andrea Kopecky
Attorney for Plaintiff
SAN FRANCISCO BAYKEEPER

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By:
/s/ Anna Le May
Anna Le May
Attorney for Defendant
PREMIER RECYCLE

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STIPULATION TO CONTINUE CASE MGMT CONFERNCE

Civil No. C 13-01695 HRL

[PROPOSED] ORDER

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GOOD CAUSE APPEARING,
October 29, 2013
1. The Case Management Conference shall be continued to___________________ at 1:30
pm.
2. The Parties’ Rule 26(f) Report and Joint Case Management Statement shall be filed no
October 22, 2013
later than ________________.
3. The Parties shall make initial disclosures or state objections in their Rule 26(f) Report no
October 22, 2013
later than _____________________.
IT IS SO ORDERED.

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9/23/13
Date: ______________

NORTHERN DISTRICT OF CALIFORNIA

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____________________________________
Honorable Howard R. Lloyd
United States District Court

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STIPULATION TO CONTINUE CASE MGMT CONFERENCE

Civil No. C 13-01695-HRL