Jayni Foley Hein (Bar No. 258261), Andrea Kopecky (Bar No. 276366), SAN FRANCISCO BAYKEEPER, San Francisco, California, Attorneys for Plaintiff, BAYKEEPER.
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES; [PROPOSED] ORDER Fed.R.Civ.P. 26(f); L.R. 16-10
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, per a previous Stipulation and Order of the Court, the Initial Case Management Conference was continued until September 10, 2013 at 1:30 p.m.;
WHEREAS, per a previous Stipulation and Order of the Court, the Initial Case Management Conference was continued until October 1, 2013 at 1:30 p.m.;
WHERAS, the Parties submitted ADR certifications and stipulated to ADR process by mediation on September 17, 2013;
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 two (2) weeks;
NOW, THEREFORE, THE PARTIES STIPULATE AS FOLLOWS:
1. The Case Management Conference shall be continued to October 22, 2013 at 1:30 pm, or as soon ...