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California Sportfishing Protection Alliance, A Non-Profit Corporation v. Verco Decking

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


October 3, 2012

CALIFORNIA SPORTFISHING PROTECTION ALLIANCE, A NON-PROFIT CORPORATION,
PLAINTIFF,
v.
VERCO DECKING, INC., A CORPORATION,
DEFENDANT.

The opinion of the court was delivered by: The Hon. Susan Illston United States District Judge

JOINT STIPULATION TO EXTEND 20 UPCOMING LITIGATION DEADLINES TO ACCOMMODATE CONTINUING SETTLEMENT NEGOTIATIONS AND [PROPOSED] ORDER_______

WHEREAS, Plaintiff California Sportfishing Protection Alliance ("Plaintiff") and Defendant Verco Decking, Inc. ("Defendant"), following a further settlement conference before 27 Magistrate Judge Spero on September 5, 2012, have reached an agreement in principle to resolve 28 all claims by Plaintiff; Farella Braun Martel LLP 235 Montgomery Street, 17th Floor San Francisco, CA 94104 Jt. Stip. to Extend Lit. Deadlines to Accommodate (415) 954-4400

Settlement Negotiations & [Proposed] Order 23505\3284697.1

WHEREAS, Plaintiff and Defendant are optimistic that the terms of a final written settlement or consent agreement will be reached in the next 30 days;

WHEREAS, Plaintiff and Defendant agree that it is appropriate to reschedule upcoming summary judgment deadlines and an upcoming further case management conference by 5 approximately 30 days to facilitate further settlement negotiations; and 6

WHEREAS, the parties agree that adjusting the appearances and deadlines listed below will not have a significant impact on the case schedule. 8

IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff and Defendant, through their respective counsel, to respectfully request that the Court set the following 10 appearances and deadlines: 11 November 1, 2012: Last day for Defendant to file early partial summary judgment motion.

November 15, 2012: Last day for Plaintiff's opposition.

November 21, 2012: Last day for Defendant's reply.

December 7, 2012, or the Court's first available date thereafter: Hearing on Defendant's early partial summary judgment motion.

December 7, 2012, or the Court's first available date thereafter: Further case management conference.

December 31, 2012: Last day for amendment of pleadings.

Dated: September 27, 2012 FARELLA BRAUN MARTEL LLP 21 By:/s/ Matthew E. Bostick 20 22 Matthew E. Bostick 23 Attorneys for Defendant VERCO DECKING, INC. Dated: September 27, 2012 LOZEAU DRURY LLP 25 By:/s/ Michael R. Lozeau (as authorized on 9/26/2012) 24 26 Michael R. Lozeau Attorneys for Plaintiff CALIFORNIA SPORTFISHING PROTECTION ALLIANCE Farella Braun Martel LLP 235 Montgomery Street, 17th Floor San Francisco, CA 94104 Jt. Stip. to Extend Lit. Deadlines to Accommodate Settlement Negotiations & [Proposed] Order - 2 - 23505\3284697.1 (415) 954-4400 The following revised appearance dates and deadlines shall apply in the above-captioned 5 case and shall replace the current corresponding appearance dates and deadlines: 6 November 1, 2012: Last day for Defendant to file early summary judgment motion.

November 15, 2012: Last day for Plaintiff's opposition. November 21, 2012: Last day for Defendant's reply. December 7, 2012, or _______________: Hearing on Defendant's early summary judgment motion.

December 7, 2012, or ______________: Further case management conference.

December 31, 2012: Last day for amendment of pleadings.

IT IS SO ORDERED.

Dated: ________________, 2012

Farella Braun Martel LLP 235 Montgomery Street, 17th Floor San Francisco, CA 94104 Jt. Stip. to Extend Lit. Deadlines to Accommodate

20121003

© 1992-2012 VersusLaw Inc.



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