Alpha Dyno Nobel v. Willis of Texas, Inc.

Filing 15

STIPULATION and ORDER 14 signed by Senior Judge William B. Shubb on 10/6/2015 granting an extension of time for defendant to respond to plaintiff's complaint from 10/7/2015 up to and including 10/16/2015. (Kirksey Smith, K)

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DOWNEY BRAND LLP
ANTHONY L. VIGNOLO (Bar No. 203933)
MATTHEW J. WEBER (Bar No. 227314)
AVALON J. FITZGERALD (Bar No. 288167)
621 Capitol Mall, 18th Floor
Sacramento, CA 95814-4731
Telephone:
916.444.1000
Facsimile:
916.444.2100
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendant
WILLIS OF TEXAS, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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DOWNEY BRAND LLP

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ALPHA DYNO NOBEL, a California
corporation,

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Plaintiff,

Case No. 2:15-cv-01745-WBS-CKD
STIPULATION FOR 9 DAY EXTENSION
OF TIME TO RESPOND TO COMPLAINT

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v.
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WILLIS OF TEXAS, INC., a Texas
corporation,

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Defendant.

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1422645.1

STIPULATION FOR 9 DAY EXTENSION OF TIME TO RESPOND TO COMPLAINT

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TO THE COURT, ALL PARTIES, AND THEIR COUNSEL OF RECORD;

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Pursuant to Local Rules 143 and 144 of the United States District Court for the Eastern

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District of California, Defendant Willis of Texas (“Defendant”), by and through its counsel,

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Avalon J. Fitzgerald of Downey Brand LLP, and Plaintiff ALPHA Dyno Nobel (“Plaintiff”), by

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and through its counsel, Kathleen C. Lyon, stipulate and agree as follows:

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Because Plaintiff and Defendant are currently negotiating a tolling and cooperation

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agreement, Defendant is granted an extension of nine (9) days to respond to Plaintiff’s Complaint

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in this matter, from October 7, 2015, up to and including October 16, 2015.

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SO STIPULATED.

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DATED: October 6, 2015

DOWNEY BRAND LLP

DOWNEY BRAND LLP

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By: /s/ Avalon J. Fitzgerald
AVALON J. FITZGERALD
Attorney for Defendant
WILLIS OF TEXAS, INC.

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DATED: October 6, 2015

ARONOWITZ SKIDMORE LYON, APLC

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By: /s/ Kathleen C. Lyon (as authorized on 10/6/15)
KATHLEEN C. LYON
Attorney for Plaintiff
ALPHA DYNO NOBEL

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IT IS SO ORDERED.

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Dated: October 6, 2015

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1422645.1

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STIPULATION FOR 9 DAY EXTENSION OF TIME TO RESPOND TO COMPLAINT