The opinion of the court was delivered by: Judge: Hon. Samuel Conti
STIPULATION TO CONTINUE DISCOVERY DEADLINES PENDING MEDIATION; [PROPOSED] ORDER
I. REQUEST AND STIPULATION RE CONTINUING DISCOVERY DEADLINES this action on Defendant Waste Management of Alameda County, Inc. ("WMAC") on September 4, WHEREAS, Plaintiff California Sportfishing Protection Alliance served the Complaint in 2008;
WHEREAS, Defendant filed its answer in this action on September 30, 2008;
WHEREAS, the parties filed a joint case management conference statement on November 13, 2008; engaged in and are continuing to engage in discussions and negotiations to fully resolve this matter and have made significant progress on a potential settlement;
WHEREAS, both before and after the filing and service of the Complaint, the parties have
WHEREAS, the parties conferred in an ADR conference call on December 17, 2008, with
Daniel Bowling, an ADR Program Staff Attorney for the Northern District of California, and 13 decided to engage in a mediation to be scheduled during January 2009 to help reach a settlement; both the initial disclosures and the written discovery that has already been served, to February 25,
WHEREAS, the parties agreed to extend the deadlines for all written discovery, including 2009, in order to focus their efforts on the mediation settlement discussions; weeks of the mediation should the mediation not result in a settlement;
WHEREAS, the parties agreed to schedule and conduct a Rule 34 site inspection within two
THEREFORE, IT IS HEREBY STIPULATED by and among Plaintiff California
Sportfishing Protection Alliance and Defendant Waste Management of Alameda County, Inc. that the parties shall have to and including February 25, 2009 to complete pending written discovery and
Stipulation to Continue Discovery Deadlines Pending Mediation; initial disclosures, and that a Rule 34 site inspection shall take place within two weeks of an 2 unsuccessful mediation.
WASTE MANAGEMENT OF ALAMEDA ...