Hulsey et al v. Pacific Gas and Electric Company et al

Filing 20

STIPULATION AND ORDER re 18 Stipulation extending time to answer, filed by Wellington Energy Inc.. Signed by Judge Edward M. Chen on 8/14/13. (bpf, COURT STAFF) (Filed on 8/14/2013)

Hulsey et al v. Pacific Gas and Electric Company et al

Doc. 20

1 NOEL EDLIN, ESQ. (SBN 107796)
[e-mail]
2 FRED M. BLUM, ESQ. (SBN 101586)

[e-mail]
3 ERIN K. POPPLER, ESQ. (SBN 267724)

[e-mail]
4 BASSI, EDLIN, HUIE & BLUM LLP

500 Washington Street, Suite 700
5 San Francisco, CA 94111
Telephone: [phone]

6 Facsimile: [phone]
7 Attorneys for Defendant

WELLINGTON POWER CORPORATION
8

9

UNITED STATES DISTRICT COURT

10

NORTHERN DISTRICT OF CALIFORNIA

11

OAKLAND DIVISION

12

13-CV-3355-EMC
PATRICIA ADAMS, WINIFRED THOMAS, )
14 LINDA CREEL, AND ABRAM PERLSTEIN,) STIPULATION BETWEEN
13 ROMAN HULSEY, CHRISTINA QUINN, ) Case No. 3:

) WELLINGTON POWER CORP. AND

15 Plaintiffs, ) PLAINTIFFS FOR FURTHER

) EXTENSION OF THE DEADLINE FOR

16 vs. ) DEFENDANT TO FILE AND SERVE A
) RESPONSIVE PLEADING TO

17 PACIFIC GAS AND ELECTRIC ) PLAINTFFS' FIRST AMENDED

19 )
)
20

COMPANY, WELLINGTON ENERGY INC.,) COMPLAINT
18 LANDIS AND GRY,; AND DOES 1-20, )

INCLUSIVE, )
Defendants. )
)

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STIPULATION BETWEEN WELLINGTON POWER CORP. AND PLAINTIFFS FOR FURTHER EXTENSION OF THE
DEADLINE FOR DEFENDANT TO FILE AND SERVE A RESPONSIVE PLEADING TO PLAINTFFS' FIRST AMENDED
COMPLAINT

Dockets.Justia.com

Defendant WELLINGTON POWER CORPORATION ("Wellngton") and Plaintiffs

2 ROMAN HULSEY, CHRISTINA QUIN, PATRICIA ADAMS, WINIFRED THOMAS,
3 LINDA CREEL, and ABRAM PERLSTEIN ("Plaintiffs"), by and through their respective

5 RECITALS

4 counsel, stipulate as follows:

6 1. On June 7, 2013, Plaintiffs filed their First Amended Complaint ("F AC") in the San

California (Case No. CGC-13-531837) (the

the State of

7 Francisco Superior Court of

8 "state couii action"). Wellington is named as a defendant in the state court action.

9 2. On July 18,2013, Defendant PACIFIC GAS AND ELECTRIC COMPANY filed with

10 this Court a notice of removal of Plaintiffs' state court action.
11 3. At the time the notice of removal was filed, Wellington had not yet appeared in the state

12 court action and, consequently, was not served with the notice. Counsel for Wellington
13 did not learn a notice of

14 4. Upon learning of

removal had been filed until July 26, 2013.
the notice of

removal, Wellngton's counsel immediately contacted

15 Plaintiffs' counsel to confirm that the previous agreement the parties reached in the state

16 court action to extend Wellington's deadline to fie and serve a responsive pleading until

17 August 14, 2013, would be honored in this federal proceeding.
18 5. Plaintiffs' counsel agreed to give Wellington until August 14,2013, to file and serve a

19 responsive pleading in this above-captioned matter.
20 6. On August 13,2013, in light of

the breadth of

the factual and legal issues raised in the

21 F AC, Wellington's counsel contacted Plaintiffs' counsel to request to further extend the
22 deadline to file and serve a responsive pleading and/or motion in this above-captioned

23 matter until August 19,2013.
24 7. Plaintiffs' counsel agreed to extend the deadline to fie and serve a responsive pleading

25 and/or motion until August 19,2013.
26

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718965

2

STIPULATION BETWEEN WELLINGTON POWER CORP. AND PLAINTIFFS FOR FURTHER EXTENSION OF THE
DEADLINE FOR DEFENDANT TO FILE AND SERVE A RESPONSIVE PLEADING TO PLAINTFFS' FIRST AMENDED
COMPLAINT

STIPULATION
2

L

3

Wellngton hereby stipulate that WeHington has until
serve a responsive

19,

to

motion in the above-captioned matter.

EDLIN, &
6

7

1 N

8

Attorneys for Defendant
WELLINGTON POWER CORPORATION

LAW

R. OVERETl

RT

THE
UNITED

27

A

H

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n

M. Che

FO

NO

dward
Judge E

R NIA

DERED

O OR
IT IS S

LI

UNIT
ED

8/14/13

S DISTRICT
TE
C
TA

RT
U
O

S

Attorneys for

N

D IS T IC T
R

OF

C

718965

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BETWEEN WELLINGTON POWER emU'. AND I'LAIN11FFS ICOll FURTlIER OF

DEADLINE FOR DEFENDANT TO FILE AND SERVE A RESPONSIVE PLEADING TO FIRST AMEN1)JW
COMPlAINT

1 Re: Roman Hulsey, et aL. v. Pacific Gas & Electric Company, et aL.
United States District Court, Northern District Case No. 3:13-CV-3355-EMC
2

CERTIFICATE OF SERVICE - ELECTRONIC TRANSMISSION

"

.J

STATE OF CALIFORNIA/COUNTY OF San Francisco

4

San Francisco. I
am over the age of eighteen (18) years and not a party to the within action. My business
address is BASSI, EDLIN, HUIE & BLUM LLP, 500 Washington Street, Suite 700, San
Francisco, California 94111.
I am a citizen of

5

6

the United States and an employee in the County of

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On the date executed below, I electronically served the document(s) via ECF File &
Serve for USDC Northern District of California, described below, on the recipients designated
on the Transaction Receipt located on the ECF File & USDC Northern District of California
website.

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STIPULATION BETWEEN WELLINGTON POWER CORP. AND

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PLAINTIFFS FOR FURTHER EXTENSION OF THE DEADLINE FOR DEFENDANT

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TO FILE AND SERVE A RESPONSIVE PLEADING TO PLAINTFFS' FIRST

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AMENDED COMPLAINT

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On the following parties:

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PLEASE SEE SERVICE LIST PROVIDED ON THE ECF WEBSITE
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-L BY ELECTRONIC FILING: I caused the above document to be served by ECF to
the following names on the service list provided by ECF, and;

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I declare under penalty of perjury that the foregoing is true and correct and that this
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document is executed on August 13,2013, at San Francisco, California.

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/s/ BRIDGETTE C. BURDICK

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BRIDGETTE C. BURDICK

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719021

PROOF OF SERVICE