The opinion of the court was delivered by: Richard Seeborg United States District Judge
STIPULATION AND [PROPOSED] ORDER REGARDING CASE MANAGEMENT SCHEDULE
In accord with the Court's directive at the October 6, 2011 case management conference and Civil Minute Order (Oct. 6, 2011) (Docket Doc. No. 176), Ecological Rights Foundation ("ERF") 3 and Pacific Gas & Electric Company ("PG&E") stipulate to and jointly propose the following case 4 management schedule for managing the next phases of litigation (which shall be limited to 5 adjudicating liability and remedy for the four PG&E facilities located at: (a) 24300 Clawiter Road, 6 Hayward, California; (b) 4801 Oakport Street, Oakland, California; (c) 2555 Myrtle Avenue, 7 Eureka, California; and (d) 1099 West 14th Street, Eureka, California ("the Facilities"): standing due.
expert reports) from any experts that it will use to support its motion for summary judgment 15 concerning liability for ERF's Clean Water Act ("CWA") claims.
17 expert reports and rebuttal expert reports) from any experts that it will use to support its cross 18 motion for summary judgment concerning liability for ERF's CWA claims. 19
20 reports) from any rebuttal experts that it will use to respond to PG&E's CWA liability experts. 21
22 or personnel who assisted the parties' CWA experts or were relied upon by these experts (including 23 but not limited to people who assisted in gathering or analyzing samples or provided information to 24 the experts concerning whether storm water runoff from the Facilities reaches waters of the United 25 States).
--October 27, 2011: Cross motions for summary judgment on standing due.
--November 10, 2011: Oppositions to cross motions for summary judgment on standing due.
--November 25, 2011: Replies in support of cross motions for summary judgment on
--December 8, 2011, 10 A.M.: Hearing on cross motions for summary judgment on standing.
--January 19, 2012: Deadline for ERF to provide Rule 26 expert disclosures (including
--February 16, 2012: Deadline for PG&E to provide Rule 26 expert ...