Joint Motion for Extension of Time to File - In the Matter of Union Oil Company of California,

W
Document Sample
scope of work template
							                                                                                                   PUBLIC

                                   UNITED STATES OF AMERICA
                              BEFORE THE FEDERAL TRADE COMMISSION
                                        WASHINGTON D.C.


In the Matter of
                                                              Docket No. 9305
UNION OIL COMPANY OF CALIFORNIA,
a corporation.


             JOINT MOTION FOR EXTENSION OF TIME TO FILE REPLIES
             TO POST TRIAL BRIEFS AND PROPOSED FINDINGS OF FACT

         Counsel for Respondent Union Oil Companyof Californiaand ComplaintCounseljointly request

a modification of Your Honor's Order on Post Trial Briefs which set April 13,2005 as the deadlinefor

filing concurrent reply briefs and replies to proposed findingsof fact. Counsel respectfblly request atwo-

week extensionof the deadline to April 27,2005 to file concurrentreply briefs and replies to proposed

findings of fact. Both parties filed post-trial briefs over 300 pages in length and filed findings of fact over

500 pages in length. Counsel requestthis two-week extension so as to provide sufiicienttime to fulfillYour

Honor's request that the parties file high-quality responses that will be of assistance to Your Honor.

                                   Respectfully Submitted,

By:                    >&/c          A   L~             By:      b-        C --/W
      Chong S. Park                                           Martin R. Lueck
      David Corn                                              David W. Beehler
      Peggy Bayer Femenella                                   Sara A. Poulos
      Lisa Fialco                                             Diane L. Simerson
      Sean Gates                                              Bethany D. Krueger
      John Roberti
      Lore Unt                                          Counselfor Union Oil Company of California
                                                        Robins, Kaplan, Miller & Ciresi L.L.P.
Counsel Supporting the Complaint                        2800 LaSalle Plaza
Bureau of Competition                                   800 LaSalle Avenue
Federal Trade Commission                                Minneapolis, MN 55402-20 15
Washington, DC 20580                                    Phone: 61 2-349-8500
Phone: 202-326-2372                                     Fax: 612-339-4181
Fax: 202-326-4962

Dated: March       \c ,2005.
and

GIBSON, DUNN & CRUTCHER, LLP
   Joseph Kattan, P.C.
   Chris Wood

1050 Connecticut Avenue, N.W.
Washington, D.C. 20036-5306
Phone: 202-55-8500
Fax: 202-530-9558
                                         UNITED STATES OF AMEJ;UCA
                                    BEFORE THE FB'bERAL TRADE COMMISSION
                                                    WASHINGTON D.C.
                  --


           In the Matter of
                                                                      Docket No. 9305
           UNION OIL COMPANY OF CALIFORNIA,
           a oorpmlion.




                       Counsel for Respondent Union Oil Company of California and Complamt Counrrel jointly
           request a modification of Yow How's Order on Post Trial Brief&which sat April 13.2005 as the

           deadline for filing concurrent reply briefs and replies to proposd findings of k.Comtd
                                                                                           t
           respectfldly q u w r a hvo-week cxtmsion ofthe d d n o t April 27,2005 to file concurrant r g l y
                                                                  o
            bricfi and raplies to proposed f i n d i i offwt, Both partits filed post-trial Mcfs over 309 page8 in

            ltngth d filed findings offaot over 500 pages in length. Cormeel r ~ p u e sthis two-weds cxtcnoion
                                                                                         t

            sa as to provide sufficient time to    fulfill Your Honor's req
            responses that will be of assistance to Your Honor.
                                                                             rr
                                                                             I/
                                                                                  that the p d a s file him-quality
                                                                                        k'      -


            By:
                Chong S PI&
                        .
                David Conn
                Peggy Bayer F ~ c n e 1 l a                           Sara A. Poulos
                Ljsa Fidco                                            Diane L.Sirnorson
                Sean Gatca                                                      .
                                                                      Bethay D Kruegsr
                Jafm RoboJti
                Lore Unt                                          CounseEfor Vnim Oil Company o Cul~onria
                                                                                                    f
                                                                  Robins, Krqrlan, Miller & Cfxbdi L.L.P.
            Courl~elSupprlSng the Complrrlnt                      2800 M a l l e Plaza
            Burcan of Conrpetition                                800 LaSalle Avenue
            Federal hada Commission                               Mimroapolis. M N 5 5402-20 15
            Wahington, DC 20580                                     h ;
                                                                  P m 612-349-8500
            Phone; 202-326-2372                                   Fax: 612-339-4181
            Fax: 202-326-4962

            Dated: Marsh        / g ,-,2005.
PAGE 2Q a RCVDAT W W O 10:53:49 M[ e StandardTime] SVR:MP4lGHTFAW3 * D R 2 CSID:2023263496 DURATION(nm6):0100
                    O5           CW                                   NM
                                                                                         PUBLIC


                           UNITED STATES OF AMERICA
                      BEFORE THE FEDERAL TRADE COMMISSION
                                WASHINGTON D.C.


In the Matter of
                                                      Docket No. 9305
UNION OIL COMPANY OF CALIFORNIA,
a corporation.


  lPROPOSED1 ORDER ON JOINT MOTION FOR EXTENSION OF TIME TO FILE
     REPLIES TO POST TRIAL BRIEFS AND PROPOSED FINDINGS OF FACT

       On March 18,2005, Counsel for Respondent Union Oil Company of Californiaand Complaint

Counsel filed a Joint Motion for Extension of Time to File Replies to Post Trial Briefs and Proposed

Findings of Fact. The Parties' motion is hereby GRANTED. The February 3,2005 Order on Post Trial

Briefs is hereby modified to reflect the following new deadline:


                      April 27,2005          Deadline for filing concurrent
                                             reply briefs and replies to
                                             proposed findings of fact




ORDERED:


                                              ~.%ichaelChappell
                                              Administrative Law Judge

Dated: March         ,2005.
                                   CERTIFICATE OF SERVICE

        I hereby certify that on March 18,2005, I caused the original and two paper copies by hand-
delivery and an electroniccopy by e-mail of the parties' Joint Motion for Extension of Time to File Replies
to Post Trial Briefs and Proposed Findings of Fact to be delivered for filing to:

                                     Donald S. Clark, Secretary
                                     Federal Trade Commission
                                     600 Pennsylvania Ave. NW, Rm.H-159
                                     Washington, DC 20580
                                     secretary@ftc.gov

       I hereby certify that on March 18,2005, I also caused two paper copies of the parties' Joint
Motion for Extension of Time to File Replies to Post Trial Briefs and Proposed Findingsof Fact to be
delivered via hand-delivery to:

                                     Office of Administrative Law Judges
                                     Federal Trade Commission
                                     600 Pennsylvania Ave. NW
                                     Washington, DC 20580
                                     Attention: The Honorable D. Michael Chappell

       I hereby certify that on March 18,2005, I also caused two paper copies of the parties' Joint
Motion for Extension of Time to File Replies to Post Trial Briefs and Proposed Findings of Fact to be
served upon the persons listed below via hand-delivery:

                                     Geoffrey Oliver, Esq.
                                     Chong S. Park, Esq.
                                     Bureau of Competition
                                     Federal Trade Commission
                                     601 New Jersey Avenue NW, Drop 6264
                                     Washington, DC 20001



                                                       h
                                                 ~ u s Dale

						
Related docs