Opinion
Case No.: CV 11-02372 PSG
10-06-2011
GLOBAL COMMUNITY MONITOR, a non-profit corporation Plaintiff, v. ENVIRONMENTAL RESOURCE RECOVERY, INC. dba VALLEY RECYCLING, INC., a corporation Defendant.
LAWRENCE P. RAMIREZ, (State Bar No. 141550) LINDSEY R. ADAMS (State Bar No. 260600) THE LITIGATION LAW GROUP Attorneys for Defendant ENVIRONMENTAL RESOURCE RECOVERY, INC. 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 GLOBAL COMMUNITY MONITOR
LAWRENCE P. RAMIREZ, (State Bar No. 141550)
LINDSEY R. ADAMS (State Bar No. 260600)
THE LITIGATION LAW GROUP
Attorneys for Defendant ENVIRONMENTAL RESOURCE RECOVERY, INC.
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 GLOBAL COMMUNITY MONITOR
STIPULATION AND [ Proposed ] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE
Judge: Magistrate Judge Paul S. Grewal
CMC Date: October 11, 2011
Time: 2:00 PM
WHEREAS Plaintiff GLOBAL COMMUNITY MONITOR filed its complaint in the above-entitled matter on May 13, 2011;
WHEREAS Defendant ENVIRONMENTAL RESOURCE RECOVERY, INC. agreed to a waiver of service of said complaint and service was completed on August 29, 2011;
WHEREAS an answer or motion pursuant to Rule 12 in response to Plaintiff's complaint is not due until October 28, 2011;
WHEREAS this Court previously granted Plaintiff GLOBAL COMMUNITY MONITOR's request to continue the Case Management Conference from August 2, 2011 at 2:00 PM to October 11, 2011 in light of ongoing efforts between the parties toward a settlement arrangement;
WHEREAS the parties continue their efforts to reach a settlement before moving forward with litigation and have made further steps toward this end;
WHEREAS the parties and their counsel do not wish to needlessly expend the time resources of the Court in a case that appears headed toward a cooperative resolution;
WHEREAS efforts toward cooperative resolution would be best served with additional time to afford both more time to complete a settlement agreement and to submit it to the 45-day review period of the Environmental Protection Agency and Department of Justice pursuant to 40 C.F.R. § 135.5;
IT IS HEREBY AGREED AND STIPULATED, that the Case Management Conference presently set for October 11, 2011 at 2:00 PM in this matter shall be continued to December 20, 2011 at 2:00 PM.
IT IS SO STIPULATED.
THE LITIGATION LAW GROUP
Lawrence P. Ramirez, Esq.
Lindsey R. Adams, Esq.
ATTORNEYS FOR DEFENDANT[UP]
ENVIRONMENTAL RESOURCE
RECOVERY, INC.
(VALLEY RECYCLING)
LOZEAU DRURY, LLP
DOUGLAS J. CHERMAK
[UP]ATTORNEYS FOR PLAINTIFF
GLOBAL COMMUNITY MONITOR
(Counsel unavailable for physical signature; Signature authorized via electronic mail as of October 3, 2011 (See Adams Decl. ¶10.)
[ PROPOSED ] ORDER:
PURSUANT TO STIPULATION IT IS SO ORDERED that the Case Management Conference presently set for October 11, 2011 at 2:00 PM in this matter shall be continued to December 20, 2011 at 2:00 PM.
Magistrate Judge Paul S. Grewal
United States Magistrate Judge