In Re: Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation

Filing 4174

LETTER addressed to Judge Shira A. Scheindlin from Pamela R. Hanebutt dated 02/18/2015 re: Stipulation of Dismissal of Insurance Claims Against CITGO. Document filed by Citgo Petroleum Corporation(formerly known as Cities Service RMT Corporation), Citgo Refining and Chemicals Company L.P.. (Attachments: # 1 Stipulation of Dismissal of Insurance Claims Against CITGO, # 2 Text of Proposed Order)(Hanebutt, Pamela)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re Methyl Tertiary-Butyl Ether
(“MTBE") Products Liability Litigation

Master File No. 1:00-1898 (SAS)
MDL No. 1358

This document pertains to:
Commonwealth of Pennsylvania v. Exxon Mobil
Corporation, et al., Case No. 14-cv-06228

STIPULATION OF DISMISSAL OF INSURANCE CLAIMS AGAINST CITGO
WHEREAS Plaintiffs have agreed to dismiss without prejudice their insurance claims (as
defined below) against CITGO Petroleum Corporation and CITGO Refining and Chemicals
Company L.P. (collectively “CITGO”);
WHEREAS the parties have agreed to jointly request that the Court enter the attached
proposed order of dismissal:
THE PARTIES HEREBY STIPULATE AND AGREE that Count VII (subrogation),
Count VIII (unjust enrichment) and Count IX (Pennsylvania Storage Tank and Spill Prevention
Act) of the Amended Complaint, which collectively are defined as the “Insurance Claims,” are
dismissed without prejudice as to CITGO. All other claims in the Amended Complaint remain
pending and unaffected by this Stipulation.
THE PARTIES FURTHER STIPULATE AND AGREE that each of the parties to this
stipulation shall bear and pay its own costs, expenses, and attorneys’ fees heretofore incurred in
connection with the claims made against CITGO in Counts VII, VIII and IX of the Amended
Complaint.
SO STIPULATED.

Dated: February 18, 2015

THE COMMONWEALTH OF PENNSYLVANIA,
BY AND THROUGH PENNSYLVANIA
ATTORNEY GENERAL KATHLEEN G. KANE,
THE PENNSYLVANIA INSURANCE
DEPARTMENT, THE PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL
PROTECTION, AND THE PENNSYLVANIA
UNDERGROUND STORAGE TANK
INDEMNIFICATIN FUND
By:

s/ Stephen A. Corr
Stephen A. Corr ([e-mail])
Special Counsel to the Commonwealth of
Pennsylvania
STARK & STARK, P.C.
777 Township Line Road, Suite 120
Yardley, Pennsylvania 19067
Ph. [phone]
Fax [phone]

CITGO PETROLEUM CORPORATION AND
CITGO REFINING AND CHEMICALS
COMPANY L.P.
By:

s/ Pamela R. Hanebutt
Nathan P. Eimer ([e-mail])
(New York Bar No. 1976067)
Pamela R. Hanebutt
([e-mail])
Lisa S. Meyer ([e-mail])
EIMER STAHL LLP
224 South Michigan Avenue, Suite 1100
Chicago, IL 60604
Ph. 312-660-7600
Fax [phone]