Case No. 3:17-cv-00321-EMC

STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE, ETC. AND [PROPOSED] ORDER - 1

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JAMES R. ARNOLD (SBN 56262)

JOHN A. BEARD (SBN 301405)

THE ARNOLD LAW PRACTICE (East Bay Office)

3685 Mt. Diablo Blvd., Suite 331

Lafayette, CA 94549

Telephone: (925) 284-8887

Facsimile: (925) 284-1387

Email: jarnold@arnoldlp.com

jbeard@arnoldlp.com

Attorneys for Defendant

RICHARD DAPELO

dba QUALITY STAINLESS TANKS

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

CALIFORNIA SPORTFISHING

PROTECTION ALLIANCE, etc.,

Plaintiff,

v.

RICHARD DAPELO, etc., et al.,

Defendants.

Case No. 3:17-cv-00321-EMC

STIPULATION TO CONTINUE CASE

MANAGEMENT CONFERENCE AND

ASSOCIATED DEADLINES; AND

[PROPOSED] ORDER

Civil L.R. 6-2

Plaintiff California Sportfishing Protection Alliance and Defendant Richard Dapelo

respectfully submit this stipulation and proposed order as follows:

WHEREAS, Plaintiff and Defendant1(collectively, the Parties) have been negotiating

in good faith to attempt to reach a settlement in this action; and

WHEREAS, the Parties are in continuing settlement discussions and are working on

the specific terms of a settlement; and

WHEREAS, the Court, at the Parties’ request, modified the Court’s schedule for this

matter on March 23, 2017 (Docket No. 16), and May 9, 2017 (Docket No. 20) by rescheduling

the dates for Defendant’s response to the complaint, the initial Case Management Conference,

1 The Parties have filed their stipulation to dismiss putative defendant Quality Stainless Tanks. See Doc. No. 27,

filed Aug. 9, 2017.
Case No. 3:17-cv-00321-EMC

STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE, ETC. AND [PROPOSED] ORDER - 2

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and associated deadlines; and

WHEREAS, the Court, after Defendant’s declination of magistrate jurisdiction issued

its Case Management Conference Order in Reassigned Case on July 12, 2017 (Docket No. 26), setting the initial Case Management Conference for August 24, 2017, with related dates as set

by the Court, the Local Rules and the Federal Rules of Civil Procedure;

WHEREAS, the Parties wish to attempt to conclude their settlement negotiations and

the specific terms of a settlement within the next thirty (30) days.

NOW, THEREFORE, THE PARTIES STIPULATE AS FOLLOWS:

The Court is requested to:

(a) Continue the Case Management Conference to October 5, 2017, or as soon

thereafter as may be convenient for the Court;

(b) Continue all deadlines pursuant to Fed. R. Civ. P. 26 currently based on the August

24, 2017 Case Management Conference date to the new date for the Case Management

Conference.

DATED: August 10, 2017 THE ARNOLD LAW PRACTICE

By: /s/ James R. Arnold

JAMES R. ARNOLD

JOHN A. BEARD

Attorneys for Defendant

RICHARD DAPELO

DATED: August 10, 2017 AQUA TERRA AERIS LAW GROUP LLP

By: /s/ Anthony M. Barnes

ANTHONY M. BARNES

Attorneys for Plaintiff

CALIFORNIA SPORTFISHING

PROTECTION ALLIANCE

//

//
Case No. 3:17-cv-00321-EMC

STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE, ETC. AND [PROPOSED] ORDER - 3

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ATTESTATION FOR E-FILING

I hereby attest pursuant to Civil L.R. 5-1(i)(3) that I have obtained concurrence in the

filing of this document from the signatories prior to filing.

DATED: August 10, 2017 By: /s/ John A. Beard
Case No. 3:17-cv-00321-EMC

STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE, ETC. AND [PROPOSED] ORDER - 4

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[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED. The Case Management Conference

shall be October 5, 2017, and the Case Management Statement due September 28, 2017. All

related deadlines are reset accordingly.

DATED: ______________

______________________ EDWARD M. CHEN

United States District Judge

8/15/17

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Edward M. Chen