City of Merced Redevelopment Agency v. Exxon Mobil Corporation, et al

Filing 121

STIPULATION AND ORDER EXTENDING DEADLINES FOR FILING OF COST BILLS AND OBJECTIONS signed by District Judge Lawrence J. O'Neill on February 18, 2015. (Munoz, I)

1 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
A Limited Liability Partnership
Including Professional Corporations
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JEFFREY J. PARKER, Cal. Bar No. 155377
3 WHITNEY JONES ROY, Cal. Bar No. 211541
333 South Hope Street, 48th Floor
4 Los Angeles, California 90071-1448
Telephone: [phone]
5 Facsimile: 213-620-1398
[e-mail]
6 [e-mail]
7 Attorneys for Defendant
EXXON MOBIL CORPORATION
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(submitted with permission of all parties)
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION

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13 CITY OF MERCED
REDEVELOPMENT AGENCY, et. al.,
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Plaintiff,
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v.
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EXXON MOBIL CORPORATION;
17 EXXON CORPORATION;
CHEVRON U.S.A., INC.;
18 CONOCOPHILLIPS COMPANY,
F/K/A PHILLIPS PETROLEUM
19 COMPANY, INDIVIDUALLY AND
AS SUCCESSOR-IN-INTEREST BY
20 MERGER TO TOSCO
CORPORATION; SHELL OIL
21 COMPANY; KINDER MORGAN
ENERGY PARTNERS, L.P.;
22 EQUILON ENTERPRISES LLC;
SFPP, L.P.; TESORO
23 CORPORATION; TESORO
REFINING AND MARKETING
24 COMPANY and DOES 1 THROUGH
200, inclusive,
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Defendants.
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Case No. 1:08-cv-00714-LJO-GSA
STIPULATION AND ORDER
EXTENDING DEADLINES FOR
FILING OF COST BILLS AND
OBJECTIONS
Complaint Filed: April 7, 2008

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SMRH:436462685.1

STIPULATION AND ORDER EXTENDING
DEADLINES FOR FILING OF COST BILLS AND OBJECTIONS

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Defendants Chevron U.S.A. Inc., Exxon Mobil Corporation (formerly known

2 as Exxon Corporation), Shell Oil Company, Equilon Enterprises LLC, Tesoro
3 Corporation, and Tesoro Refining and Marketing Company (collectively,
4 “Defendants”) and plaintiff Merced Designated Local Authority, as successor
5 agency to the Redevelopment Agency of the City of Merced (“Plaintiff”) submit the
6 following stipulation:
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WHEREAS, on February 4, 2015, the Court granted in part Defendants’

9 motion for summary judgment (CM/ECF Document No. 118) and the Clerk entered
10 judgment in accordance therewith (CM/ECF Document No. 119).
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WHEREAS, Defendants are each preparing their respective cost bills.

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WHEREAS, due to the duration of this case and amount of cost information

15 to be collected and reviewed for the cost bills, it has been a time-consuming process
16 that is taking longer than the 14 days allowed under E.D. Cal. Local Rule 292(b).
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WHEREAS, Plaintiff anticipates that it will need more than the week allowed

19 under E.D. Cal. Local Rule 292(c) to prepare its objection to the four Defendants’
20 cost bills.
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WHEREAS, the parties are engaged in discussions that, if successful, would

23 resolve all cost bills and appeals.
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SMRH:436462685.1

STIPULATION AND (PROPOSED) ORDER EXTENDING
DEADLINES FOR FILING OF COST BILLS AND OBJECTIONS

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THEREFORE, the parties stipulate to a two-week extension for Defendants to

2 file their cost bills and two weeks for Plaintiff to file its opposition to any cost bills.
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Dated: February 18, 2015
Respectfully submitted,
SHEPPARD, MULLIN, RICHTER &
HAMPTON LLP

KING & SPALDING LLP

By

By

MILLER & AXLINE

HUNTON & WILLIAMS LLP

/s/ Jeffrey J. Parker
JEFFREY J. PARKER
Attorneys for Defendant
EXXON MOBIL CORPORATION

By

/s/ Michael D. Axline
MICHAEL D. AXLINE
Attorney for Plaintiff

By

MERCED DESIGNATED LOCAL
AUTHORITY, AS SUCCESSOR
AGENCY TO THE
REDEVELOPMENT AGENCY OF
THE CITY OF MERCED

/s/ Charles C. Correll, Jr.
CHARLES C. CORRELL, JR.
Attorneys for Defendant
CHEVRON U.S.A. INC.

/s/ Colleen P. Doyle
COLLEEN P. DOYLE
Attorney for Defendants
TESORO CORPORATION AND
TESORO REFINING AND
MARKETING COMPANY

SEDGWICK LLP

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By

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/s/ Peter C. Condron
PETER C. CONDRON
Attorney for Defendants
SHELL OIL COMPANY AND
EQUILON ENTERPRISES LLC

22 IT IS SO ORDERED.
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Dated:

/s/ Lawrence J. O’Neill

February 18, 2015

UNITED STATES DISTRICT JUDGE

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SMRH:436462685.1

STIPULATION AND (PROPOSED) ORDER EXTENDING
DEADLINES FOR FILING OF COST BILLS AND OBJECTIONS

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