IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA
March 29, 2012
UNITED STATES OF AMERICA, AND SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT,
FORWARD, INC., DEFENDANT.
BENJAMIN B. WAGNER United States Attorney SYLVIA QUAST Assistant United States Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2740 Facsimile: (916) 554-2900 Attorneys for the United States of America
STIPULATION FOR LEAVE OF COURT TO FILE SECOND AMENDED COMPLAINT AND ORDER
WHEREAS during the course of discovery, the Plaintiffs learned of facts that they believe form the basis for violations beyond those alleged in the First Amended Complaint on file with the Court (Docket # 6);
WHEREAS the Plaintiffs have prepared a proposed Second Amended Complaint, attached hereto as Exhibit A, which encompasses the recently discovered alleged violations;
WHEREAS the parties to this action have now arrived at a settlement of this action that is embodied in the Proposed Consent Decree filed today and that by its terms encompasses the alleged violations in the proposed Second Amended Complaint as well as those already included in the First Amended Complaint; // //
Stipulation To File Second Amended Complaint
NOW THEREFORE the parties jointly request that the Court grant leave to the Plaintiffs to file the proposed Second Amended Complaint.
In light of the foregoing stipulation, leave to file the Second Amended Complaint attached as
Exhibit A to the stipulation, is hereby granted.
IT IS SO ORDERED.
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