Opinion
Case No. 3:12-CV-06274-SI
03-06-2013
CALIFORNIA SPORTFISHING PROTECTION ALLIANCE, a non-profit corporation; Plaintiff, v. GEORGIA-PACIFIC GYPSUM LLC, a Delaware limited liability company; GEORGIA-PACIFIC BUILDING PRODUCTS LLC, a Delaware limited liability company; RICK TURNER, an individual; MANOJ MATHUR, an individual; ROBERT CYPHERS, an individual; JEREMIAH DAVIS, an individual; MICHAEL WOODY, an individual; FRED CURCIO, an individual, Defendants.
LAW OFFICES OF ANDREW L. PACKARD Emily J. Brand Attorneys for Plaintiff California Sportfishing Protection Alliance COX CASTLE & NICHOLSON LLP Robert P. Doty Attorneys for Defendants Georgia-Pacific Gypsum LLC, et al.
ANDREW L. PACKARD (State Bar No. 168690)
EMILY J. BRAND (State Bar No. 267564)
Law Offices of Andrew L. Packard
100 Petaluma Blvd. N. Ste. 301
Petaluma, CA 94952
Tel: (707) 763-7227
Fax: (415) 763-9227
E-mail: andrew@packardlawoffices.com
emily@packardlawoffices.com
Attorneys for Plaintiff California Sportfishing Protection Alliance
STIPULATION TO CONTINUE CASE
MANAGEMENT SCHEDULE;
DECLARATION OF EMILY BRAND;
[PROPOSED] ORDER [Civil L.R. 16-2(d)]
Plaintiff California Sportfishing Protection Alliance ("CSPA") together with Defendants Georgia-Pacific Gypsum LLC, Georgia-Pacific Building Products LLC, Robert Cyphers, Jeremiah Davis, Michael Woody, Fred Curcio, Rick Turner and Manoj Mathur hereby stipulate and move to continue the remaining case management schedule dates set in the Order dated December 11, 2012 (Court Doc #3) and amended by the Case Management Conference Order (Court Doc #8) to be continued by a period of thirty (30) days.
LAW OFFICES OF ANDREW L. PACKARD
_________________
Emily J. Brand
Attorneys for Plaintiff
California Sportfishing Protection Alliance
COX CASTLE & NICHOLSON LLP
__________
Robert P. Doty
Attorneys for Defendants
Georgia-Pacific Gypsum LLC, et al.
DECLARATION OF EMILY BRAND
1. I am an attorney for Plaintiff California Sportfishing Protection Alliance, herein.I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed in Berkeley, CA on February 28, 2013.
2. This action is a complaint for declaratory and injunctive relief and civil penalties brought against Defendants Georgia-Pacific Gypsum LLC, Georgia-Pacific Building Products LLC, Robert Cyphers, Jeremiah Davis, Michael Woody, Fred Curcio, Rick Turner and Manoj Mathur ("Defendants"), for current and ongoing violations of the Clean Water Act, 33 U.S.C. § 1251 to § 1387. The action was filed on December 11, 2012.
3. Plaintiff has not served Defendants at this time.
4. The parties are in active negotiations to settle the matter and hope to reach a complete resolution of this matter soon. Plaintiff has presented Defendants with a settlement proposal and Defendants have provided substantive comments on this agreement.
5. The parties agree that it is in their mutual best interests to request a short continuation of all Court deadlines to allow the parties to continue the settlement negotiations.
6. I am therefore requesting all current deadlines be extended thirty days, to allow Plaintiff and Defendants to come to a settlement agreement.
Law Offices of Andrew L. Packard
By: ___________
Emily J. Brand
Attorneys for Plaintiff
[PROPOSED ORDER]
GOOD CAUSE APPEARING, it is hereby, ORDERED, that the deadlines set forth in the Clerk's Notice Setting Case Management Conference be extended as follows:
+-----------------------------------------------------------------------------+ ¦Last day to file Rule 26(f) Report, complete initial disclosures ¦- April 5,¦ ¦or state Objection and file Case Management Statement ¦2013 ¦ +------------------------------------------------------------------+----------¦ ¦Initial Case Management Conference ¦- April ¦ ¦ ¦19, 2013 ¦ +-----------------------------------------------------------------------------+
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UNITED STATES DISTRICT JUDGE