United States of America, ex rel. et al v. Carolina Liquid Chemistries, Corp.

Filing 45

STIPULATION AND ORDER re 40 STIPULATION WITH PROPOSED ORDER Joint Stipulation regarding Briefing Schedule filed by Randy Reagan, Carolina Liquid Chemistries, Corp., Patricia Shugart, James Longfield, Phil Shugart Motion to Dism iss due by 3/18/2019. Responses due by 4/8/2019. Replies due by 4/22/2019. Motion Hearing set for 5/16/2019 at 2:00 PM in San Francisco, Courtroom 9, 19th Floor before Judge Jon S. Tigar. Signed by Judge Jon S. Tigar on February 7, 2019. (wsn, COURT STAFF) (Filed on 2/8/2019)

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NIALL P. McCARTHY (SBN 160175)
[e-mail]
JUSTIN T. BERGER (SBN 250346)
[e-mail]
ERIC J. BUESCHER (SBN 271323)
[e-mail]
COTCHETT, PITRE & McCARTHY, LLP
San Francisco Airport Office Center
840 Malcolm Road
Burlingame, CA 94010
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Relators
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UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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UNITED STATES OF AMERICA ex rel.
RANDY REAGAN and JAMES LONGFIELD;
and STATE OF CALIFORNIA, STATE OF
TEXAS, STATE OF MICHIGAN, STATE OF
NEW YORK, STATE OF NORTH CAROLINA
ex rel. RANDY REAGAN and JAMES
LONGFIELD;

CASE NO. CV 13-01497 KAW
JOINT STIPULATION AND [PROPOSED]
ORDER REGARDING BRIEFING
SCHEDULE

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Plaintiffs,
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v.
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CAROLINA LIQUID CHEMISTRIES, CORP., a
Delaware Corporation; PATRICIA SHUGART,
an individual; and PHIL SHUGART, an
individual;
Defendants.

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♼

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LAW OFFICES
COTCHETT, PITRE &
MCCARTHY, LLP

JOINT STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING
SCHEDULE

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JOINT STIPULATION
IT IS HEREBY STIPULATED AND AGREED UPON by and between all parties through
and by their counsel of record:
WHEREAS, Relators Randy Reagan and James Longfield filed their Amended Complaint on
October 18, 2018;

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WHEREAS, the United States of America declined intervention on October 22, 2018;

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WHEREAS, the Court issued an Order to Unseal on October 23, 2018,

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WHEREAS, Relators sent over a service packet to Defendants Patricia Shugart and Phil

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Shugart’s counsel to accept service of the Summons, Complaint, Waiver of Service of Summons, and
additional service documents on November 6, 2018

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WHEREAS, Relators sent over a service packet to Defendant Carolina Liquid Chemistries,

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Corp.’s counsel to accept service of the Summons, Complaint, Waiver of Service of Summons, and

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additional service documents on November 28, 2018;

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WHEREAS, the parties have met and conferred regarding a briefing schedule;

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WHEREAS, the parties jointly stipulate to the following briefing schedule:

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

Defendants’ Motion to Dismiss is due March 18, 2019;

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

Relator’s Opposition to the Motion to Dismiss brief is due April 8, 2019;

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

Defendants’ Reply Brief in Support of the Motion to Dismiss is due April 22,
2019; and

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

Defendants’ Motion to Dismiss will be noticed for May 16, 2019 at 1:30 p.m.
before the Hon. Kandis A. Westmore.

IT IS SO STIPULATED.

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Dated: January 31, 2019

COTCHETT, PITRE & McCARTHY, LLP

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♼

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LAW OFFICES
COTCHETT, PITRE &
MCCARTHY, LLP

By:

/s/ Eric J. Buescher
ERIC J. BUESCHER

Attorneys for Relators
JOINT STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING
SCHEDULE

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ORRICK, HERRINGTON & SUTCLIFFE, LLP

~ ~~-----------~~~· ~

RA;;;;&~-

By: _____

Attorneys for Defendant Carolina Liquids Chemistries, Corp.

ORRICK, HERRINGTON & SUTCLIFFE, LLP

Attorneys for Defendant Patricia Shugart

ORRICK, HERRINGTON & SUTCLIFFE, LLP

By:

---~~ .L-__:___________
-~--~ 3..~
--~.
RANJnG§KEY

Attorneys for Defendant Phil Shugart

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LAW OFF ICES
COTCHETI, PITRE &
MCCARTIIY, LLP

JOINT STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING
SCHEDULE

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[PROPOSED] ORDER
PURSUANT TO THE JOINT STIPULATION, it is hereby ordered the briefing schedule
regarding Defendants’ Motion to Dismiss is as follows:

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

Defendants’ Motion to Dismiss is due March 18, 2019;

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

Relator’s Opposition to the Motion to Dismiss brief is due April 8, 2019;

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

Defendants’ Reply Brief in Support of the Motion to Dismiss is due April 22,
2019; and

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

A hearing is scheduled for Defendants’ Motion to Dismiss on May 16, 2019, at
2:00 p.m.
1:30 p.m.

IT IS SO ORDERED.
Date: February 7, 2019
HON. KANDIS A. WESTMORE
Hon. Jon S. Tigar

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♼

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LAW OFFICES
COTCHETT, PITRE &
MCCARTHY, LLP

JOINT STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING
SCHEDULE

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