United States of America et al v. Forward, Inc.

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 7/28/11: Defendant FORWARD, INC. shall file a First Amended Answer to the First Amended Complaint within fourteen (14) days of this Order. (Kaminski, H)

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THOMAS M. BRUEN (SBN 63324)
ERIK A. REINERTSON (SBN 218031)
LAW OFFICES OF THOMAS M. BRUEN
A Professional Corporation
1990 N. California Boulevard, Suite 620
Walnut Creek, CA 94596
Telephone: [phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]

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JEFFREY B. SETNESS (SBN 96773)
MAYALL, HURLEY, KNUTSEN, SMITH & GREEN
2453 Grand Canal Boulevard, Second Floor
Stockton, California 95207
Telephone:
[phone]
Facsimile:
[phone]
E-mail:
[e-mail]

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Attorneys for Defendant FORWARD, INC.
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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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UNITED STATES OF AMERICA, and SAN
JOAQUIN VALLEY UNIFIED AIR
POLLUTION CONTROL DISTRICT,

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Plaintiffs,

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v.

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Case No.: 2:11-cv-00590 EFB
STIPULATION AND ORDER GRANTING
LEAVE FOR DEFENDANT FORWARD,
INC. TO FILE FIRST AMENDED
ANSWER TO FIRST AMENDED
COMPLAINT; ORDER THEREON.

FORWARD, INC.,

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[Complaint filed: March 3, 2011]
Defendant.

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Defendant FORWARD, INC. (“Forward”), Plaintiffs UNITED STATES OF AMERICA,
and SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT, by and
through their respective counsel, stipulate as

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follows:
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________________________________________________________________________________
STIPULATION AND ORDER FOR LEAVE TO FILE
FIRST AMENDED ANSWER

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1.

Forward may amend its Answer to the First Amended Complaint by adding an

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Eighth Affirmative Defense, by correcting a mislabeled heading, and by withdrawing its demand for

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a jury trial. A First Amended Answer to the First Amended Complaint that includes this amendment

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is attached as Exhibit A.

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2.

Within ten (10) days of the Court’s execution of the Order granting Defendant leave

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to amend their Answer, Defendants shall file and serve a First Amended Answer (substantially in

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the form of Exhibit A) to the First Amended Complaint filed against them by Plaintiffs in this

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action.

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DATED: July 27, 2011

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/s/ Sylvia Quast
SYLVIA QUAST
Assistant U.S. Attorney
Attorneys for the United States

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BENJAMIN B. WAGNER
United States Attorney

DATED: July 27, 2011

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SAN JOAQUIN VALLEY UNIFIED
AIR POLLUTION CONTROL DISTRICT
/s/ Catherine T. Redmond
CATHERINE T. REDMOND
District Counsel
Attorneys for the San Joaquin Valley
Unified Air Pollution Control District

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DATED: July 27, 2011

LAW OFFICES OF THOMAS M. BRUEN
A Professional Corporation
/s/ Erik A. Reinertson
ERIK A. REINERTSON
Attorneys for Forward, Inc.

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________________________________________________________________________________
STIPULATION AND ORDER FOR LEAVE TO FILE
FIRST AMENDED ANSWER

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ORDER
Pursuant to stipulation of the Parties, and good cause appearing:
It is ORDERED that:
Defendant FORWARD, INC. shall file a First Amended Answer to the First Amended

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Complaint within fourteen (14) days of this Order.

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IT IS SO ORDERED.

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Date: July 28, 2011.
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HON. EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE

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________________________________________________________________________________
STIPULATION AND ORDER FOR LEAVE TO FILE
FIRST AMENDED ANSWER