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California Sportfishing Protection Alliance, et al v. West Sonoma County Disposal Service

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


July 25, 2012

CALIFORNIA SPORTFISHING PROTECTION ALLIANCE, ET AL., PLAINTIFFS,
v.
WEST SONOMA COUNTY DISPOSAL SERVICE, INC., ET AL., DEFENDANTS.

The opinion of the court was delivered by: Magistrate Judge JudgeJoseph C. Spero

JOINT STIPULATION TO EXTEND UPCOMING LITIGATION DEADLINES TO ACCOMMODATE CONTINUING SETTLEMENT NEGOTIATIONS

WHEREAS, Plaintiffs California Sportfishing Protection Alliance and Petaluma River Council ("Plaintiffs") and Defendants West Sonoma County Disposal Service, Inc., Redwood 3 Empire Disposal, Inc., Novato Disposal Service, Inc., James Ratto, James R. Salyers, and Rick 4 Holliday ("Defendants") are in continuing settlement negotiations before Magistrate Judge Corley, 5 and are scheduling an appearance before Judge Corley early in August 2012 for a further settlement 6 conference; 7

WHEREAS, the following deadlines have been set for the case: Expert disclosure August 24, 2012 Further Case Management Conference September 14, 2012 at 1:30 p.m. Expert rebuttal disclosure September 24, 2012 Non-expert discovery cutoff November 16, 2012 Expert discovery cutoff November 16, 2012 Dispositive motion hearing January 18, 2013 at 1:30 p.m. Case management conference to set trial date February 15, 2013 at 1:30

WHEREAS, Plaintiffs and Defendants agree that it is appropriate to reschedule these deadlines and appearances by approximately 60 days to facilitate further settlement negotiations;

WHEREAS, the parties believe it would be in their mutual best interest to extend all deadlines and the trial date in this matter an additional two months in order to allow the parties to engage in further settlement discussions and potentially resolve this action; and 23

WHEREAS, the parties believe that such an extension would conserve the resources of the court; 25

IT IS HEREBY STIPULATED AND AGREED by and between Plaintiffs and Defendants, 26 through their respective counsel, to respectfully request that the Court vacate the above deadlines and 27 appearances and reset them as follows: 28

Expert disclosure October 26, 2012 Further Case Management Conference October 19, 2012 at 1:30 p.m. Expert rebuttal disclosure November 21, 2012 Non-expert discovery cutoff January 11, 2013 Expert discovery cutoff January 11, 2013 Dispositive motion hearing March 29, 2013 at 1:30 p.m. Case management conference to set trial date April 26, 2013 at 1:30

Dated: July 23, 2012 Respectfully submitted, 11 LOZEAU DRURY LLP 12 13 By: /s/ Michael R. Lozeau* Michael R. Lozeau 14 Attorney for Plaintiffs California Sportfishing Protection Alliance 15 and Petaluma River Counsel 16 Dated: July 23, 2012 BRISCOE IVESTER & BAZEL LLP 17 18 By: /s/ Lawrence S. Bazel Lawrence S. Bazel 19 Attorneys for Defendants West Sonoma County Disposal Service, Inc.; Redwood Empire Disposal, Inc.; Novato Disposal, Inc.; James Ratto; James R. Salyers; 20 21 and Rick Holliday *I hereby attest that I have on file all holograph signatures for any signatures indicated by a 23 "conformed" signature (/S/) within this efiled document. ES DIST I 22 PURSUANT TO STIPULATION, IT IS SO ORDERED. T R A CT S T C O 24 D U 25 _________________ E

20120725

© 1992-2012 VersusLaw Inc.



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