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Tri-Valley Cares v. United States Department of Energy

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA San Francisco Division


April 4, 2011

TRI-VALLEY CARES,
PLAINTIFFS,
v.
UNITED STATES DEPARTMENT OF ENERGY, DEFENDANTS.

The opinion of the court was delivered by: Honorable Richard Seeborg United States District Judge

*E-Filed 4/4/11*

SCOTT YUNDT (CSB #242595) TRI-VALLEY CARES 2582 Old First Street Livermore, California 94550 Telephone: (925) 443-7148 Facsimile: (925) 443-0177 Email: scott@trivalleycares.org Attorneys for Plaintiffs TRI-VALLEY CARES

STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE INITIAL CASE MANAGEMENT CONFERENCE

Plaintiff Tri-Valley CAREs, Defendant United States Department of Energy, by and through their respective counsel, hereby stipulate as follows:

WHEREAS, pursuant to the Clerk's Notice filed 2/16/11, the initial Case Management Conference in the above captioned case was scheduled to be held on April 14, 2011 at 10:00 a.m . in Courtroom 3 on the 17 Floor of the United States Courthouse, 450th Golden Gate Avenue, San Francisco; and WHEREAS, Plaintiffs and Defendants desire to reschedule the initial Case Management Conference in the above captioned case to provide the parties with four additional weeks to discuss the outstanding claims and prepare the Joint Case Management Statement.

THEREFORE, IT IS HEREBY STIPULATED AND AGREED by Plaintiffs and Defendants, through their respective counsel of record, as follows:

1. The Case Management Conference in the instant case, originally scheduled to be held on April 14, 2011 at 10:00 a.m . in Courtroom 3 on the 17 th Floor of the United States Courthouse, 450 Golden Gate Avenue, San Francisco, shall be rescheduled to May 12, 2011 at 10:00 a.m. in that same location.

2. The parties shall file a Joint Case Management Statement at least one week prior to the Conference.

3. The foregoing agreement is not intended, and may not be cited by any party, as admission of any issue of fact or law in this or any other judicial or administrative proceeding.

DECLARATION OF CONSENT

Pursuant to General Order No. 45, Section X(B) regarding signatures, I attest under penalty of perjury that concurrence in the filing of this document has been obtained from Abraham Simmons.

Dated this 1st day of April, 2011

/s/ Scott J. Yundt Scott J. Yundt Attorney for Plaintiff

1. The Case Management Conference in the instant case, originally scheduled to be held on April 14, 2011 at 10:00 a.m . in Courtroom 3 on the 17 th Floor of the United States Courthouse, 450 Golden Gate Avenue, San Francisco, shall be rescheduled to May 12, 2011 at 10:00 a.m. in that same location.

IT IS SO ORDERED.

Presented by:

/s/Scott Yundt Scott Yundt (CSB# 242595) Attorney for Plaintiffs

20110404

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