Free Motion for Extension of Time to File Answer - District Court of Delaware - Delaware

Case 1 :07-cv-00716-JJF-IVIPT Document 7 Filed 02/11/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PLUMBERS AND PIPEFITTERS LOCAL :
UNION NO. 74 ANNUITY PLAN, :
PLUMBERS AND PIPEFITTERS LOCAL :
NO. 74 WELFARE PLAN, :
PLUMBERS AND PIPEFITTERS LOCAL :
UNION NO. 74 PENSION PLAN :
(formerly the Pipefitters Local Union :
No. 80 and Employers Joint Pension Fund), :
SCHOLARSHIP FUND OF THE PLUMBERS :
AND PIPEFITTERS LOCAL UNION NO. 74, :
PLUMBERS AND PIPEFITTERS LOCAL NO. 74 :
APPRENTICESHIP FUND, PIPEFITTERS :
UNION NO. 74 EDUCATIONAL/PAC FUND, :
and LOCAL UNION NO. 74 OF THE UNITED :
ASSOCIATION OF JOURNEYMEN AND :
APPRENTICES OF THE PLUMBING AND 2
PIPEFITTING INDUSTRY OF THE :
UNITED STATES AND CANADA, AFL-CIO :
(formerly Pipetitters Local No. 80), 2
Plaintiffs,
v. Civil Action No. 07-716 —JJF (MPT)
JOHNSON CONTROLS, INC.,
successor to York Int’l Corp. :
a/k/a York Int’l, ;
Defendant.
JOINT STIPULATION AND ORDER
FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
Plaintiffs and Defendant, by and through their undersigned counsel, hereby agree and
stipulate to an extension of time through and including March 14, 2008 for Defendant to respond
to the Complaint in this action. The extension of time will facilitate the parties’ continued
attempts to amicably work through the audit and contribution issues and possibly resolve this
action without further litigation. Since the last extension, Defendant has completed transmitting

Case 1 :07-cv-00716-JJF-I\/IPT Document 7 Filed 02/11/2008 Page 2 of 2
all relevant payroll infomation to Plaintiffs and P1aintiffs’ auditors are analyzing and processing
such infomation. The parties continue to jointly work towards a possible amicable resolution
and are hopeful that a settlement can be reached by March 14, 2008 - the end of the requested
extension period.
Respectfully submitted,
YOUNG CONAWAY STARGATT FOX ROTHSCHILD LLP
& TAYLOR, LLP
By: /s/ Timothy J. Snyder (No. 2408) By: /s/ Gregory B. Williams (No. 4195)
Timothy J. Snyder (No. 2408) Gregory B. Williams (No. 4195)
Ctu·tis J. Crowther (No. 323 8) Sophia Siddiqui (No. 4914)
The Brandywine Building Citizens Bank Center
1000 West Street, 17th Floor 919 N. Market Street, Suite 1300
P.O. Box 391 P.O. Box 2323
Wilmington, DE 19801 Wilmington, DE 19899
(302) 571-6645 (302) 622-4211
(302) 576-3336 (fax) (302) 656-8920 (fax)
[email protected] [email protected]
Of Counsel: Of Counsel:
Shanna M. Cramer, Esquire David J .B. F roiland, Esquire
Jennings Sigmond, P.C. Foley & Lardner LLP
The Penn Mutual Towers, 16m Floor 777 East Wisconsin Avenue
510 Walnut Street Milwaukee, Wisconsin 53202
Philadelphia, PA 19106-3683 (414) 297-5579
(215) 351-0674
Attorneys for Plaintiffs Attorneys for Defendant
Date: February 11, 2008
GRANTED and so ORDERED this day of February 2008.
J.

Case 1:07-cv-00716-JJF-MPT

Document 7

Filed 02/11/2008

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Case 1:07-cv-00716-JJF-MPT

Document 7

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