Jayni Foley Hein (Bar No. 258261), Andrea Kopecky (Bar No. 276366), SAN FRANCISCO BAYKEEPER, San Francisco, California, Attorneys for Plaintiff, BAYKEEPER.
Anna Le May, Attorney for Defendant, PREMIER RECYCLE.
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES; [PROPOSED] ORDER
HOWARD R. LLOYD, District Judge.
Plaintiff San Francisco Baykeeper ("Baykeeper") and Defendant Premier Recycle Company ("Premier Recycle") in the above-captioned action respectfully submit this stipulation as follows:
WHEREAS, Baykeeper and Premier Recycle (collectively, the "Parties") have been working together in good faith to reach a settlement in this action;
WHEREAS, the Parties have already exchanged and are currently finalizing the terms of what they anticipate will be a final Consent Decree for approval by the court;
WHEREAS, the Court's Order Setting Initial Case Management Conference and ADR Deadlines ("Scheduling Order") set the initial Case Management Conference in this matter for July 23, 2013 at 1:30 pm;
WHEREAS, per a previous Stipulation and Order of the Court, the Initial Case Management Conference was continued until August 20, 2013 at 1:30 p.m.;
WHEREAS, the Scheduling Order states that if the Initial Case Management Conference is continued, the other deadlines are continued accordingly;
WHEREAS, the Parties desire to continue negotiating settlement in good faith and anticipate reaching a final settlement in this action within the next four (4) weeks; NOW, THEREFORE, THE PARTIES STIPULATE AS FOLLOWS:
1. The Case Management Conference shall be continued to September 10, 2013 at 1:30 pm, or as soon thereafter as the Court is available.
2. The Parties' ADR certifications and stipulations to ADR process or notices of need for an ADR phone conference shall be due two weeks before the Case Management Conference.
3. The Parties' Rule 26(f) Report and Joint Case Management Statement shall be due one week before the Case Management Conference.
4. The Parties shall make initial disclosures or state objections in their Rule 26(f) Report no later than one week before ...