American Causalty Company Of Reading, Pennsylvania et al v. Western Environmental Consultants, Inc. et al.,

Filing 16

STIPULATION and ORDER signed by Senior Judge Lawrence K. Karlton on 12/23/2010 ORDERING that PG&E shall have until 1/10/2011 to answer or otherwise respond to the complaint filed by Pltfs. (Zignago, K.)

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RICHARD J. DENATALE (SBN 121416) ORRICK HERRINGTON & SUTCLIFFE LLP 405 Howard Street San Francisco, CA 94105 Telephone No. [phone] Facsimile No.: [phone] Email: [e-mail] Attorneys for Defendant PACIFIC GAS AND ELECTRIC COMPANY

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA AMERICAN CASUALTY COMPANY OF READING, PENNSYLVANIA, et al., Plaintiffs, v. WESTERN ENVIRONMENTAL CONSULTANTS, INC. et al., Defendants. CASE NO. 2:10-CV-02806-LKK-GGH

JOINT STIPULATION AND ORDER TO EXTEND RESPONSE DATE

WHEREAS Plaintiffs American Casualty Company of Reading, Pennsylvania, and National Fire Insurance Company of Hartford, successor by merger to Transcontinental Insurance Company ("Plaintiffs") served defendant Pacific Gas and Electric ("PG&E") with the complaint on file in this action on October 26, 2010; WHEREAS, the docket sheet states that PG&E's answer or other responsive pleading was initially due November 16, 2010; WHEREAS, Plaintiffs have agreed that PG&E may have until January 10, 2011 to file an answer or other responsive pleading in order to enable PG&E to obtain outside counsel to represent it in this proceeding and become familiar with the facts and legal issues herein; WHEREAS, on or about December 13, 2010, Richard DeNatale of Orrick Herrington &
-1OHS West:261059649.1

CASE NO. 2:10-CV-02806-LKK-GGH

JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND RESPONSE DATE
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Sutcliffe LLP was retained by PG&E as outside counsel in this action; WHEREAS, counsel for PG&E have not sought any previous extensions of time from the Court. Pursuant to Local Rule 144, Plaintiffs, defendant Western Environmental Consultants, Inc. ("Western") and defendant PG&E, HEREBY STIPULATE AND AGREE that PG&E shall have up to and including Monday, January 10, 2011 to answer or otherwise respond to the complaint filed by Plaintiffs. DATED: December 21, 2010 ORRICK HERRINGTON & SUTCLIFFE LLP By: /S/ Richard J. DeNatale Richard J. DeNatale Attorneys for Defendant PACIFIC GAS AND ELECTRIC COMPANY DATED: December 21, 2010 WOOLS & PEER By: /S/ John E. Peer John E. Peer

Attorneys for Plaintiffs AMERICAN CASUALTY COMPANY OF READING, PENNSYLVANIA, and NATIONAL FIRE INSURANCE COMPANY OF HARTFORD, successor by merger to TRANSCONTINENTAL INSURANCE COMPANY DATED: December 21, 2010 COVINGTON & BURLING LLP By: /S/ Esta L. Brand Esta L. Brand

Attorneys for Defendant WESTERN ENVIRONMENTAL CONSULTANTS

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CASE NO. 2:10-CV-02806-LKK-GGH

JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND RESPONSE DATE

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IT IS SO ORDERED. Dated: December 23, 2010.

-3OHS West:261059649.1

CASE NO. 2:10-CV-02806-LKK-GGH

JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND RESPONSE DATE