Free Stipulation to EXTEND Time - District Court of Delaware - Delaware

Case 1:88-cv-00263-SLR Document 366 Filed O9/05/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
)
NATURAL RESOURCES DEFENSE )
COUNCIL, INC. and DELAWARE )
AUDUBON SOCIETY, )
Plaintiffs, I
v. I C. A. N0. 88-263-SLR
TEXACO REFINING AND I
MARKETING, INC., )
Defendant. g
STIPULATION AND ORDER
EXTENDING DEADLINES FOR PRE-TRIAL MOTIONS AND ONE DEPOSITION
WHEREAS, the parties have reached a settlement in principle to resolve
their pending motions to enforce the judgment and for relief from the judgment;
WHEREAS, the parties have been negotiating the language of an
appropriate agreement documenting their settlement and have exchanged drafts of such a
document;
WHEREAS, by order of this court dated August 24, 2007, pre—trial
motions are required to be tiled by September 5, 2007 and the deadline for deposing
Roberto Llanso was extended to September 7, 2007;
WHEREAS, the parties believe their time is better spent finalizing and
executing a settlement agreement, and believe they can do so within the next week, thus
obviating the need for pre-trial motions and further discovery;
IT IS HEREBY STIPULATED and agreed by and between the parties,
subject to the approval of the Court, that:

Case 1 :88-cv-00263-SLR Document 366 Filed O9/05/2007 Page 2 of 2
The deadline for filing pre-trial motions is extended to
September 12, 2007.
The deadline for deposing Roberto Llanso is extended to
September 14, 2007.
All other deadlines set forth in the Court’s March 27, 2007 stipulated
scheduling order remain in effect.
COOCH & TAYLOR MORRIS, NICHOLS, ARSHT & TUNNELL, LLP
/s/ C. Scott Reese /s/Megan Cascio
C. Scott Reese (#2036) Richard D. Allen (#469)
824 Market Street Megan Ward Cascio (#3785)
Suite 1000 1201 North Market Street
Wilmington, DE 19899 P. O. Box 1347
(302) 652-3641 Wilmington, Delaware 19899
(302) 658-9200
NATURAL RESOURCES DEFENSE WALLACE KING DOMIKE & REISKIN, PLLC
COUNCIL Anthony F. King
Mitchell S. Bernard Julie M. Domike
Nancy S. Marks John W. Kampman
40 West 20th Street 1050 Thomas Jefferson Street, N.W.
New York, New York 1001 1 Washington, DC 20007
(212) 727-2700 (202) 204-1000
Attorneys for Plaintyjfs Attorneys for Defendant
SO ORDERED THIS _ day of September,
2007.
The Honorable Sue L. Robinson
Unites States District Court Judge
1217006
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