Continental Casualty Company v. Recology Inc.

Filing 16

ORDER granting further request to extend time to respond to the initial complaint. Signed by Judge Susan Illston on 10/6/15. (tfS, COURT STAFF) (Filed on 10/7/2015)

R NIA

NO

DERED
1 Nicholas P. Roxborough, Esq. (SBN 113540)
SO OR
[e-mail]
IT IS
2 Burton E. Falk, Esq. (SBN 100644)
[e-mail]
ston
3 Charles R. Rondeau (SBN 164136)
usan Ill
Judge S
4 [e-mail]
ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP
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5 5820 Canoga Ave., Ste. 250
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Woodland Hills, CA 91367
D IS T IC T O
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6 Tel: [phone]
Fax: [phone]
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8 Attorneys for Defendant
RECOLOGY, INC., f/k/a
9 NORCAL WASTE SYSTEMS, INC.

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S DISTRICT
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

13 CONTINENTAL CASUALTY
COMPANY, an Illinois corporation,
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CASE NO. Case No. 15-cv-03969-SI (SI)
[Complaint filed on August 31, 20151
STIPULATION TO FURTHER
EXTEND TIME TO RESPOND TO
INITIAL COMPLAINT (L.R. 6-1)

Plaintiff,

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17

VS.

18 RECOLOGY, INC., f/k/a NORCAL
WASTE SYSTEMS, INC., a California
19 corporation,

Current response date: October 7, 2015

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New response date: October 23, 2015

Defendants.

Complaint served: September 2, 2015

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23 TO THE COURT, ALL APPEARING PARTIES AND THEIR RESPECTIVE
24 ATTORNEYS OF RECORD:
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WHEREAS Defendant Recology, Inc., f/k/a Norcal Waste Systems, Inc.

26 ("Defendant"), was named as a Defendant and was served with the Summons and
27 Complaint in the above-captioned action on September 2, 2015;
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STIPULATION TO FURTHER EXTEND TIME TO RESPOND TO INITIAL COMPLAINT

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WHEREAS the parties had previously agreed to an extension of time for

2 Defendant to respond to the Complaint through and including October 7, 2015;
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WHEREAS, since that time, the parties have agreed to an informal exchange

4 of information and documents to allow Defendant to accurately and completely
respond to the Complaint, and the parties to continue to work toward defining the
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scope of the exchange and gathering responsive material;
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WHEREAS the parties wish to continue efforts for an early disposition
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of this matter;

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WHEREAS the parties have been diligent in agreeing to a further extension of
Defendant's time to respond to the Complaint;

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WHEREAS the parties have agreed to allow the stipulating Defendant until
October 23, 2015 to respond to the Complaint; and

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WHEREAS counsel for the Plaintiff and Defendant are duly authorized by
their clients to enter into this Stipulation;

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NOW, THEREFORE, IT IS HEREBY STIPULATED that Defendant
Recology, Inc., f/k/a Norcal Waste Systems, Inc., shall have a further extension of

16 time to respond to the Complaint through and including October 23, 2015.
17 DATED: October 5, 2015
ROXBOROUGH, POMERANCE, NYE &
ADREANI, LLP

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/ s / B u r t o n E . F a l k
NICHOLAS P. ROXBOROUGH
BURTON E. FALK
CHARLES R. RONDEAU
Attorneys for Defendant
RECOLOGY, INC., Vida
NORCAL WASTE SYSTEMS, INC.

B y :

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DATED: October 5, 2015

CARROLL, BURDICK & McDONOUGH
By:

/s/ Geoffrey David Godwin
GEOFFREY DAVID GOD WIN
Attorneys for Plaintiff
CONTINENTAL CASUALTY
COMPANY, an Illinois corporation

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STIPULATION TO FURTHER EXTEND TIME TO RESPOND TO INITIAL COMPLAINT