UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA

Transcription

1 Arc Ecology, et al v United States Maritime Administration, et al Doc. 0 0 IGNACIA S. MORENO Assistant Attorney General LESLIE M. HILL MICHELLE R. LAMBERT NORMAN RAVE Trial Attorneys United States Department of Justice Environmental Defense Section P.O. Box Washington, DC 00- Telephone: (0) -0 Facsimile: (0) - leslie.hill@usdoj.gov; michelle.lambert@usdoj.gov Attorneys for Defendants CHRISTIANA TIEDEMANN (Cal. Bar No. 0) Supervising Deputy Attorney General TARA L. MUELLER (Cal. Bar No. ) Deputy Attorney General Clay Street, 0th Floor P. O. Box 00 Oakland, CA -00 Telephone: (0) - (Mueller) (0) - (Tiedemann) Fax: (0) -0 Attorneys for the California Regional Water Quality Control Board, San Francisco Bay Region [Additional Counsel on Signature Page] ARC ECOLOGY, et al., UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA Plaintiffs, and CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD, v. UNITED STATES MARITIME ADMINISTRATION, et al., Defendants. Case No. :0-cv-0-GEB-KJN JOINT STIPULATION AND ORDER FOR CONTINUANCE OF PRETRIAL Dockets.Justia.com

2 0 0 following: The parties to the above captioned litigation stipulate to and respectfully propose the WHEREAS trial is currently set for June, 00; WHEREAS to allow for continued efforts to resolve this litigation, on December, 00 the parties moved to continue the trial, (Dkt. 0 and 0.), and on December, 00 the Court entered an order continuing the trial until June, 00 and the final pre-trial conference until March, 00 and requiring the final joint pretrial statement to be filed seven days before the pre-trial conference (Dkt. ); WHEREAS the parties have engaged in lengthy settlement discussions and have reached a tentative settlement subject to management and client approval, but have not yet completed the formal management or client approval process; WHEREAS the record snow storms in the Washington, D.C. area and resulting government closures have delayed the Federal defendants' work on the settlement documents and completion of the management review approval process; WHEREAS the parties expect to complete the management review and approval process by the end of March, but the current pre-trial schedule would require the parties to cease work on settlement approval and prepare their joint pre-trial statement by March, 00; and WHEREAS accordingly, in an effort to conserve judicial time and resources, the parties jointly request that the Court continue the pretrial conference presently set for March, 00 to April, 00, during which time the parties expect to complete the parties' settlement approval processes; and // THEREFORE, the parties hereby stipulate as follows: The parties request that the Court continue the Final Pretrial Conference, currently scheduled for March, 00, until April, 00, or as soon thereafter as may be convenient for the Court. For the Federal Defendants: IGNACIA S. MORENO Assistant Attorney General Civ. No. 0-0-GEB-KJN

3 0 0 February, 00 By: /s/ Michelle R. Lambert For Plaintiff-Intervenor: LESLIE M. HILL MICHELLE R. LAMBERT Trial Attorneys United States Department of Justice Environmental Defense Section P.O. Box Washington, DC 00- Telephone: (0) -0 Facsimile: (0) - EDMUND G. BROWN JR. Attorney General of the State of California February, 00 By: /s/ Christiana Tiedemann (as authorized //0) CHRISTIANA TIEDEMANN (Cal. Bar No. 0) Supervising Deputy Attorney General TARA L. MUELLER (Cal. Bar No. ) Deputy Attorney General Clay Street, 0th Floor P. O. Box 00 Oakland, CA -00 Telephone: (0) - (Mueller) (0) - (Tiedemann) Fax: (0) -0 Attorneys for the California Regional Water Quality Control Board, San Francisco Bay Region Civ. No. 0-0-GEB-KJN

4 0 0 For Environmental Plaintiffs: February, 00 By: /s/ Michael E. Wall (as authorized //0). MICHAEL E. WALL (Cal. Bar No. 0) NATURAL RESOURCES DEFENSE COUNCIL Sutter Street, 0th Floor San Francisco, California 0 Tel.: () -00; Fax: () - mwall@nrdc.org THOMAS CMAR (admitted pro hac vice) NATURAL RESOURCES DEFENSE COUNCIL North Riverside Plaza, Suite 0 Chicago, IL 00- Tel.: () -0; Fax: () - tcmar@nrdc.org SCOTT ALLEN (Cal. Bar No. ) LARIVIERE, GRUBMAN & PAYNE Upper Ragsdale Drive, Suite 00 Monterey, CA 0 Tel.: () -; Fax: () - sallen@lgpatlaw.com DAVID A. NICHOLAS (admitted pro hac vice) 0 Whitney Road Newton, MA 00 Tel.: () -; Fax: () - dnicholas@verizon.net Attorneys for plaintiffs Arc Ecology, San Francisco Baykeeper, and Natural Resources Defense Council, Inc. Civ. No. 0-0-GEB-KJN

5 ORDER The Final Pretrial Conference is rescheduled for April, 00, at :0 p.m. A joint pretrial statement is to be filed seven days prior to the hearing. It is so ORDERED. Date: //0 0 0 Civ. No. 0-0-GEB-KJN