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

Case 1 :88-cv-00263-SLR Document 365 Filed 08/22/2007 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, g
v. g C. A. N0. 88-263-SLR
TEXACO REFINING AND j
MARKETING, INC., )
Defendant. j
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, pre-trial motions are required to be filed by August 22, 2007;
WHEREAS, by agreement, the parties have scheduled one remaining
deposition, of Roberto Llanso, now set for August 24, 2007;
WHEREAS, the parties believe their time is better spent drafting and
executing a settlement agreement, and believe they can do so within the next two weeks,
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:
The deadline for filing pre-trial motions is extended to September 5, 2007.
The deadline for deposing Roberto Llanso is extended to September 7,
p 2007.

Case 1 :88-cv-00263-SLR Document 365 Filed 08/22/2007 Page 2 of 2
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 Ward 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 10011 Washington, DC 20007
(212) 727-2700 (202) 204-1000
Attorneys f0r Plczintwfv Attorneys for Dekndant
SO ORDERED THIS __ day of August,
2007.
The Honorable Sue L. Robinson
Unites States District Court Judge
1217006
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