STIPULATION TO FURTHER EXTEND TIME TO RESPOND TO INITIAL COMPLAINT (L. R. 6-1) / ALLOW FOR SUBMISSION OF STIPULATION FOR AMENDMENT OF COMPLAINT

SUSAN ILLSTON, District Judge

TO THE COURT, ALL APPEARING PARTIES, AND ALL ATTORNEYS OF RECORD:

WHEREAS, Plaintiff Continental Casualty Company "Plaintiff" filed the Complaint against Defendant Recology, Inc., f/k/a Norcal Waste Systems, Inc. ("Defendant"), on August 31, 2015;

WHEREAS, Defendant was served with the Summons and Complaint in the above-captioned action on September 2, 2015;

WHEREAS, the Parties have previously agreed to extensions of time for Defendant to respond to the Complaint through and including October 23, 2015;

WHEREAS, the Parties have also agreed to an informal exchange of information and documents to allow Defendant to accurately and completely respond to the Complaint, and the Parties to continue working toward defining the scope of the exchange and gathering responsive material;

WHEREAS, pursuant to Guideline for Professional Conduct 10, on October 16, 2015, the Parties met and conferred regarding Defendant's challenges to the allegations in the Complaint and Defendant requested, among other things, that Plaintiff amend the complaint to clarify and separate some of the allegations relating to the worker's compensation claim of Miguel Alvarez and the worker's compensation claim of Abelardo Casas;

WHEREAS, the Parties have agreed that Plaintiff will seek leave of Court to file a First Amended Complaint pursuant to stipulation;

WHEREAS, the Parties have further agreed that Defendant shall give Plaintiff sufficient time to amend the Complaint and the Parties contemplate submitting a stipulation and proposed order to the Court to file the First Amended Complaint in the immediate future;

WHEREAS, the Parties wish to continue efforts for an early disposition of this matter;

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

WHEREAS, the Parties have agreed to allow Defendant until November 13, 2015 to respond to the Complaint and that prior to this date the Parties will submit a stipulation and proposed order to file the First Amended Complaint; and

WHEREAS, counsel for the Parties are duly authorized by their clients to enter into the immediate Stipulation.

NOW, THEREFORE, IT IS HEREBY STIPULATED that Defendant Recology, Inc., f/k/a Norcal Waste Systems, Inc., shall have a further extension of time to respond to the Complaint through and including November 13, 2015.

IT IS SO ORDERED.