Gcube Insurance Services, Inc. v. Lindsay Corporation

Filing 50

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 8/8/2013 STRIKING all allegations of attorneys' fees against Project Assistance Corporation contained in 21 Third Party Complaint for negligence, equitable indemnity, equitable contribution and declaratory relief, specifically paragraphs 37, 42, 46 and the prayer for relief for the four causes of action. (Michel, G)

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Jill A. Franklin, SBN 128280
Yaron F. Dunkel, SBN 215873
SCHAFFER, LAX McNAUGHTON & CHEN
A Professional Corporation
515 South Figueroa Street, Suite 1400
Los Angeles, CA 90071
Tel: [phone]
Fax: [phone]
[e-mail]; [e-mail]
Attorneys for Defendant/Third-Party Plaintiff: LINDSAY CORPORATION

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A PROFESSIONAL CORPORATION
Timothy M. Blaine, SBN 124176
Christopher M. Egan, SBN 232301
Clayton T. Cook, SBN 260891
350 University Ave., Suite 200
Sacramento, California 95825
Tel: [phone]
Fax: [phone]
E-mails: [e-mail]; [e-mail]; [e-mail]

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Attorneys for Third-Party Defendant: PROJECT ASSISTANCE CORP. (formerly known as
MATERIAL INTEGRITY SOLUTIONS, INC.)

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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GCUBE INSURANCE SERVICES, INC., a
California corporation,

CASE NO. 2:12-cv-01163-WBS-CKD

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STIPULATION AND [PROPOSED]
ORDER TO STRIKE ATTORNEYS’
FEE CLAIM AGAINST PROJECT
ASSISTANCE CORPORATION FROM
LINDSAY CORPORATION’S THIRDPARTY COMPLAINT

Plaintiff,

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v.

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LINDSAY CORPORATION, a Delaware
corporation, and DOES 1 through 10,
inclusive,

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Complaint Filed:
Cross-Complaint Filed:

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April 30, 2012
March 1, 2013

Defendants.
____________________________________/

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STIPULATION AND [PROPOSED] ORDER TO STRIKE ATTORNEYS’ FEE CLAIM AGAINST
PROJECT ASSISTANCE CORPORATION FROM LINDSAY CORPORATION’S
THIRD-PARTY COMPLAINT
{01152312.DOCX}

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LINDSAY CORPORATION,
Third-Party Plaintiff,

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v.
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AREVA SOLAR, INC., AUSRA CA I, LLC
now known as AREVA SOLAR CA I, LLC;
SPECIAL SERVICES CONTRACTORS,
INC.; LLOYD W. AUBRY CO., INC.;
MATERIAL INTEGRITY SOLUTIONS,
INC. and ZOES 1 through 50, Inclusive,
Third-Party Defendants.
____________________________________/

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Defendant/Third-Party Plaintiff LINDSAY CORPORATION, by and through its

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attorney of record, hereby stipulates to strike all allegations of attorneys’ fees in its Third-Party

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Complaint against PROJECT ASSISTANCE CORPORATION (formerly known as

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MATERIAL INTEGRITY SOLUTIONS), specifically paragraphs 37, 42, 46 and the prayer for

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relief for the four causes of action. The parties agree to this stipulation by original or facsimile

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signatures.

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Dated: July 31, 2013

SCHAFFER, LAX, McNAUGHTON & CHEN

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By: /s/ Jill A. Franklin (authorized on 07/31/13)
Jill A. Franklin
Yaron F. Dunkel
Attorneys for Defendant/Third-Party Plaintiff
LINDSAY CORPORATION

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Dated: August 7, 2013

PORTER SCOTT
A PROFESSIONAL CORPORATION

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By: /s/ Clayton T. Cook
Timothy M. Blaine
Christopher M. Egan
Clayton T. Cook
Attorneys for Third-Party Defendant
PROJECT ASSISTANCE CORP.

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STIPULATION AND [PROPOSED] ORDER TO STRIKE ATTORNEYS’ FEE CLAIM AGAINST
PROJECT ASSISTANCE CORPORATION FROM LINDSAY CORPORATION’S
THIRD-PARTY COMPLAINT
{01152312.DOCX}

ORDER

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The parties having so stipulated, IT IS ORDERED that all allegations of attorneys’ fees

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against

PROJECT

ASSISTANCE

CORPORATION

(fka

MATERIAL

INTEGRITY

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SOLUTIONS, INC.) contained in LINDSAY CORPORATION’s Third-Party Complaint for

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negligence, equitable indemnity, equitable contribution and declaratory relief, specifically

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paragraphs 37, 42, 46 and the prayer for relief for the four causes of action, are hereby stricken.

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Dated: August 8, 2013
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STIPULATION AND [PROPOSED] ORDER TO STRIKE ATTORNEYS’ FEE CLAIM AGAINST
PROJECT ASSISTANCE CORPORATION FROM LINDSAY CORPORATION’S
THIRD-PARTY COMPLAINT
{01152312.DOCX}