1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

-1-

STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING ON TRUSTEE 

RICK BRADLEY’S MOTION FOR SUMMARY JUDGMENT

WACTOR & WICK LLP

180 Grand Avenue, Suite 950

Oakland, CA 94612

JON K. WACTOR (State Bar No. 141566)

PETER TON (State Bar. No. 232226)

WACTOR & WICK LLP

180 Grand Avenue, Suite 950

Oakland CA 94612-3572

Telephone: (510) 465-5750

Facsimile: (510) 465-5697 

Attorneys for Defendants Bradley Mining Company and Frederick W. Bradley, in his 

representative capacity as Trustee of the Worthen Bradley Family Trust

UNITED STATES DISTRICT COURT OF CALIFORNIA

NORTHERN DISTRICT

THE UNITED STATES OF AMERICA,

Plaintiff,

v.

BRADLEY MINING COMPANY, and

FREDERICK W. BRADLEY, in his representative 

capacity as Trustee of the Worthen Bradley Family 

Trust,

 Defendants.

Case No. CV-08-3968

STIPULATION AND [PROPOSED] 

ORDER TO CONTINUE THE 

HEARING ON MOTION FOR

SUMMARY JUDGMENT OF 

DEFENDANT TRUSTEE 

FREDERICK W. BRADLEY

Date: June 7, 2010 

Time: 10 a.m.

Courtroom: 12

Judge: Thelton E. Henderson

Action Filed: August 19, 2008

TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:

As provided in the proposed Order below, Plaintiff United States of America (“Plaintiff”), 

Defendant Bradley Mining Company (“BMCo”), and Defendant Frederick W. Bradley in his 

representative capacity of the Worthen Bradley Family Trust (“Trustee”) (collectively “the 

Parties”) jointly stipulate that:

Case 3:08-cv-03968-TEH Document 56 Filed 04/05/10 Page 1 of 3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

-2-

STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING ON TRUSTEE 

RICK BRADLEY’S MOTION FOR SUMMARY JUDGMENT

WACTOR & WICK LLP

180 Grand Avenue, Suite 950

Oakland, CA 94612

1. Defendant Trustee requests a Continuance of the hearing for his Motion for 

Summary Judgment which is currently set for May 3, 2010 at 10:00 a.m., in Courtroom 12, to 

June 7, 2010 at 10 a.m. so that the Parties may conclude settlement negotiations. 

2. The Continuance of the hearing on the Motion for Summary Judgment does not 

affect the scheduled Case Management Conference currently set for 1:30 p.m. on May 3, 2010. 

IT IS SO STIPULATED.

I attest that concurrence in the filing of this stipulation and [proposed] order has been 

obtained from Mr. Robert D. Mullaney, the attorney for Plaintiff United States of America.

Dated: April 2, 2010 /s/ Robert D. Mullaney 

ROBERT D. MULLANEY

Environmental Enforcement Section

U.S. Department of Justice

Attorneys for Plaintiff United States of 

America

Dated: April 2, 2010 /s/ Jon K. Wactor 

JON K. WACTOR

Wactor & Wick LLP

Attorneys for Defendants Bradley Mining 

Company and Frederick Bradley, as Trustee of the 

Worthen Bradley Family Trust

Case 3:08-cv-03968-TEH Document 56 Filed 04/05/10 Page 2 of 3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

-3-

STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING ON TRUSTEE 

RICK BRADLEY’S MOTION FOR SUMMARY JUDGMENT

WACTOR & WICK LLP

180 Grand Avenue, Suite 950

Oakland, CA 94612

[PROPOSED] ORDER

ON STIPULATION OF ALL PARTIES AND GOOD CAUSE APPEARING 

THEREFORE, it is hereby ORDERED: 

1. The Hearing set for May 3, 2010 on Defendant Trustee’s Motion for Summary 

Judgment is continued to June 7, 2010 at 10:00 a.m.

2. The Case Management Conference, which is currently set for 1:30 p.m. on May 3, 

2010, remains on the Court’s calendar.

IT IS SO ORDERED.

Date:

Hon. Thelton E. Henderson

U.S. District Court Judge

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORN

I

A

Judge Thelton E. Henderson

04/05/10

Case 3:08-cv-03968-TEH Document 56 Filed 04/05/10 Page 3 of 3