San Francisco Baykeeper v. Premier Recycle Company

Filing 27

STIPULATION AND ORDER (MODIFIED) re 25 TO CONTINUE CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES filed by Premier Recycle Company. Case Management Statement due by 11/12/2013. Case Management Conference set for 11/19/2013 01:30 PM in Courtroom 2, 5th Floor, San Jose. Signed by Judge Howard R. Lloyd on 10/22/2013. (hrllc1, COURT STAFF) (Filed on 10/22/2013)

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*E-Filed: October 22, 2013*

William W. Funderburk Jr. (SBN 176244)
Anna L. Le May (SBN 258312)
CASTELLÓN & FUNDERBURK LLP
811 Wilshire Boulevard, Suite 1025
Los Angeles, California 90017
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant Premier Recycle Company

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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 (MODIFIED)
Fed. R. Civ. P. 26(f); L.R. 16-10

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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;
WHEREAS, per a previous Stipulation and Order of the Court, the Initial Case Management
Conference was continued until October 29, 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 three (3) weeks;
NOW, THEREFORE, THE PARTIES STIPULATE AS FOLLOWS:
1. The Case Management Conference shall be continued to November 19, 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.

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STIPULATION TO CONTINUE CASE MGMT CONFERNCE

Civil No. C 13-01695 HRL

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3. The Parties shall make initial disclosures or state objections in their Rule 26(f) Report no
later than one week before the Case Management Conference.
Dated: October 17, 2013

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Respectfully submitted,

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By:

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

By:

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

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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,
1. The Case Management Conference shall be continued to___________________ at 1:30
November 19, 2013
pm.
2. The Parties’ Rule 26(f) Report and Joint Case Management Statement shall be filed no
November 12, 2013
later than ________________.
3. The Parties shall make initial disclosures or state objections in their Rule 26(f) Report no
later than _____________________.*
November 12, 2013
IT IS SO ORDERED.

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Date: ______________
10/22/13

NORTHERN DISTRICT OF CALIFORNIA

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____________________________________
Honorable Howard R. Lloyd
United States District Court

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*The Court does not intend to grant further continuances of the case management conference.

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STIPULATION TO CONTINUE CASE MGMT CONFERENCE

Civil No. C 13-01695-HRL