Filed: Dec. 28, 2015
Latest Update: Dec. 28, 2015
Summary: STIPULATION TO CONTINUE RESPONSE DATE TO THIRD PARTY COMPLAINT (Local Rule 6-1) SUSAN ILLSTON , District Judge . TO THE HONORABLE SUSAN ILLSTON, UNITED STATES DISTRICT COURT JUDGE; AND TO ALL PARTIES AND THEIR COUNSEL OF RECORD: Ed Fleming Company, Inc. d/b/a Fleming & Associates, Third Party Defendant in the above-captioned case, and Third Party Plaintiff Recology, Inc f/k/a NorCal Waste Systems, Inc., by and through their respective counsel hereby stipulate as follows: RECITALS 1. WHER
Summary: STIPULATION TO CONTINUE RESPONSE DATE TO THIRD PARTY COMPLAINT (Local Rule 6-1) SUSAN ILLSTON , District Judge . TO THE HONORABLE SUSAN ILLSTON, UNITED STATES DISTRICT COURT JUDGE; AND TO ALL PARTIES AND THEIR COUNSEL OF RECORD: Ed Fleming Company, Inc. d/b/a Fleming & Associates, Third Party Defendant in the above-captioned case, and Third Party Plaintiff Recology, Inc f/k/a NorCal Waste Systems, Inc., by and through their respective counsel hereby stipulate as follows: RECITALS 1. WHERE..
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STIPULATION TO CONTINUE RESPONSE DATE TO THIRD PARTY COMPLAINT (Local Rule 6-1)
SUSAN ILLSTON, District Judge.
TO THE HONORABLE SUSAN ILLSTON, UNITED STATES DISTRICT COURT JUDGE; AND TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
Ed Fleming Company, Inc. d/b/a Fleming & Associates, Third Party Defendant in the above-captioned case, and Third Party Plaintiff Recology, Inc f/k/a NorCal Waste Systems, Inc., by and through their respective counsel hereby stipulate as follows:
RECITALS
1. WHEREAS, Plaintiff Recology, Inc. f/k/a/Norcal Waste Systems, Inc., a California corporation filed its Third Party Complaint, in Case No. 3:15-cv-03969 on November 30, 2015 and named Ed Fleming Company d/b/a Fleming & Associates ("Fleming") as a Third Party Defendant.
2. WHEREAS, on December 2, 2015, Fleming was served by personally serving Fleming's agent for service of process.
3. WHEREAS, by virtue of the December 2, 2015 personal service, Fleming's response to the Third Party Complaint is due on December 23, 2015.
4. WHEREAS, in anticipation of being retained by Fleming to represent it, on December 21, 2015, Kenderton S. Lynch of Krafchak & Lynch contacted Third Party Plaintiff's counsel, Charles R. Rondeau, and requested an extension of time to respond to the Third Party Complaint.
5. WHEREAS, on December 21, 2015 Charles R. Rondeau agreed to an extension of time to respond to the Third Party Complaint.
6. WHEREAS, on December 22, 2015 Fleming retained Krafchak & Lynch to represent it.
7. WHEREAS, Krafchak & Lynch has had insufficient time to prepare a meaningful response to the Third Party Complaint and the Parties through their respect counsel have agreed to an extension of time to respond to the Third Party Complaint.
NOW THEREFORE, it is hereby stipulated and agreed by and between the Parties that:
STIPULATION
1. The response time for Fleming to respond to the Third Party Complaint is hereby extended to January 15, 2016.
2. This Stipulation may be executed in counterparts, which shall be considered together as a single document. Furthermore, this Stipulation may be executed by facsimile copy or PDF, and facsimile or PDF signatures will be treated as original signatures.
IT IS SO STIPULATED
