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

Filing 4517

FILING ERROR - DEFICIENT DOCKET ENTRY - LETTER MOTION for Extension of Time to File Answer to the Fifth Amended Complaint addressed to Judge Vernon S. Broderick from Katherine M. Katchen dated October 9, 2018. Document filed by Lukoil North America LLC, Lukoil Pan Americas, LLC, PJSC LUKOIL. (Attachments: # 1 Stipulation and [Proposed] Order)Filed In Associated Cases: 1:00-cv-01898-VSB, 1:08-cv-00312-VSB(Sorkin, Joseph) Modified on 10/10/2018 (db).

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October 9, 2018 VIA ECF The Honorable Vernon S. Broderick United States District Court Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 Re: KATHERINE M. KATCHEN +1 215.965.1239/fax: +1 215.965.1210 kkatchen@akingump.com MDL 1358 / MTBE, New Jersey Department of Environmental Protection, et al. v. Atlantic Richfield Co., et al., No. 1:08-cv-00312-VSB Dear Judge Broderick: We represent newly-added defendants Lukoil North America LLC, Lukoil Pan Americas, LLC, and PJSC Lukoil (“newly-added Lukoil Defendants”), which entities were added as Defendants in the above-referenced litigation by the Court’s Order of September 28, 2018, granting leave to file a Fifth Amended Complaint. The newly-added Lukoil Defendants respectfully request an extension of time through November 30, 2018, in which to answer, move or otherwise respond to the Fifth Amended Complaint. Existing Defendants Lukoil Americas Corporation and Getty Petroleum Marking Inc., represented by Matthew G. Parisi of Bleakley Platt & Schmidt, LLP, join in this request for an extension. We have conferred with counsel for Plaintiff, and they have no objection to this extension. The Parties have signed the enclosed stipulation, and we respectfully request your signature on the enclosed “Stipulation and [Proposed] Order.” Respectfully, Katherine M. Katchen cc: All Counsel of Record (via LNFS)

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