CALIFORNIA SPORTFISHING PROTECTION ALLIANCE, a non-profit corporation, Plaintiff,
CRITERION CATALYSTS & TECHNOLOGIES, L.P., a corporation, Defendant.
Michael R. Lozeau, (State Bar No. 142893), Richard T. Drury, (State Bar No. 163559), Douglas J. Chermak, (State Bar No. 233382), LOZEAU DRURY LLP, Attorneys for Plaintiff CALIFORNIA SPORTFISHING PROTECTION ALLIANCE
Douglas J. Chermak, Attorneys for Plaintiff, CALIFORNIA SPORTFISHING PROTECTION ALLIANCE
Albert Giang, (as authorized on 9/19/2013) Attorneys for Defendant, CRITERION CATALYSTS & TECHNOLOGIES, L.P.
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR RESPONSIVE PLEADING AND RESCHEDULE CASE MANAGEMENT CONFERENCE
JACQUELINE S. CORLEY, Magistrate Judge.
WHEREAS, on June 12, 2013, Plaintiff California Sportfishing Protection Alliance ("CSPA") and Defendant Criterion Catalysts & Technologies, L.P. ("Criterion") (collectively, "Parties") first entered into a stipulation acknowledging that the deadline for Criterion to file a responsive pleading was extended to August 6, 2013 and requesting that the initial Case Management Conference be rescheduled to August 22, 2013 ("June 12 Stipulation") (ECF Dkt. 7), to permit the Parties to engage in confidential settlement discussions that would resolve this matter outside of litigation. On June 12, 2013, the Court entered an order approving the June 12 Stipulation (ECF Dkt. 8).
WHEREAS, on July 26, 2013, the Parties entered into a second stipulation requesting that the deadline for Criterion to file a responsive pleading be further extended to October 1, 2013 and requesting that the initial Case Management Conference be rescheduled to October 17, 2013 ("July 26 Stipulation") (ECF Dkt.10), to permit the Parties to continue to engage in confidential settlement discussions that would resolve this matter outside of litigation. On July 29, 2013, the Court entered an order approving the July 26 Stipulation (ECF Dkt. 11).
WHEREAS, since the June 12 Stipulation and the July 26 Stipulation, the Parties have been diligently engaged in confidential settlement discussions, which are still continuing and require additional time for the Parties to fully pursue, and are in the process of evaluating proposed settlement terms.
WHEREAS, the Parties believe that further short continuances of the deadline for Criterion's responsive pleading and the initial Case Management Conference are necessary for the Parties to continue focusing on these discussions, to avoid diverting resources away from these discussions towards premature litigation, and to prevent the unnecessary expenditure of Court resources at this stage.
WHEREAS, the Parties have agreed, upon the Court's approval, to extend the time within which Criterion shall respond to the Complaint from October 1, 2013 to November 15, 2013, and to reschedule the Case Management Conference from October 17, 2013 to December 5, 2013.
WHEREAS, no Parties would be prejudiced by the proposed continuances.
THEREFORE, IT IS STIPULATED by and between the Parties, through their respective counsel, as follows:
1. Criterion's deadline for responding to the Complaint shall be extended from October 1, 2013 to November 15, 2013.
2. The deadline to file the Joint Case Management Statement shall be extended from October 10, 2013 to November 25, 2013.
3. The Case Management Conference shall be continued from 1:30 p.m. on October 17, 2013 to 1:30 ...