IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, VANIA IIOI Plaintiffs, V. PITTSBURGH WATER AND SEWER AUTHORITY, JORDAN TAX SERVICE, VEOLIA WATER NORTH AMERICA, Defendants. CORDS FUSION Ll.? TY PA p? 2): A. can.? LL. .. Ch!- -3 PH 3113*. ALL DEPT OF COURT 1W JURY TRIAL DEMANDED CIVIL DIVISION G.D. 15-8738 MOTION FOR STAY OF PROCEEDINGS fu? IU-mem Counsel of record for these parties:- John P. Corcoran, Jr., Esquire Pa. ID. 74906 Ronald D. Amrhein, Esquire Pa. ID. 58845 David A. Borkovic Pa. ID. No. 23005 Of Counsel Jones, Gregg, Creehan Gerace, LLP 411 Seventh Ave, Suite 1200 Pittsburgh, PA 15219 W6 nemeIW-moo OZ :2 Hal 8- Sll? IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, JAMES WOJCICKI, individually; PROVENTUS CIVIL DIVISION HOLDINGS, LLC, A Limited Liability Company; GALA LIMITED a Limited Partnership; and on behalf of themselves and all others similarly situated, G.D. 15?8738 Plaintiffs, v. PITTSBURGH WATER AND SEWER AUTHORITY, JORDAN TAX SERVICE, VEOLIA WATER NORTH AMERICA, Defendants. NOTICE OF PRESENTATION PLEASE TAKE NOTICE that the within MOTION FOR STAY OF PROCEEDINGS will be presented before the Honorable Judge R. Stanton Wettick, Jr., on Friday, June 3, 2016, at 2:00 pm, or as soon thereafter as meets the convenience of the Court. JONES, GREGG, CREEHAN GERACE, LLP . ?i in BY: co/Bo?oRAN, JR., ESQUIRE FOR THE CLASS REPRESENTATIVES AND THE CLASS PLAINTIFFS IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, JAMES WOJCICKI, individually; PROVENTUS CIVIL DIVISION HOLDINGS, LLC, A Limited Liability Company; GALA LIMITED a Limited Partnership; and on behalf of themselves and all others similarly situated, G.D. 15-8738 Plaintiffs, V. PITTSBURGH WATER AND SEWER AUTHORITY, JORDAN TAX SERVICE, VEOLIA WATER NORTH AMERICA, Defendants. MOTION FOR STAY OF PROCEEDINGS AND NOW, come the Plaintiffs, on behalf of themselves and all others similarly situated, by and through their attorneys, John P. Corcoran, Jr., Esquire, and Jones, Gregg, Creehan Gerace and file the following Motion for Stay of Proceedings and in support thereof state as follows: 1. The parties are in settlement negotiations at this time and have been tendering proposals for resolution of the above?referenced claim. 2. The parties, specifically The Pittsburgh Water and Sewer Authority, and the plaintiffs, are attempting to resolve this matter without the necessity of further occurrence of legal fees. 3. The plaintiffs have agreed to dismiss without prejudice Jordan Tax Service from this litigation so therefore only The Pittsburgh Water and Sewer Authority and Veolia related entities are involved in this case. 4. Counsel for the Plaintiffs has to review this matter with class counsel and the representative Plaintiffs in order to finalize a resolution to the claims. 5. Based on the foregoing, it is respectfully requested thatthis Honorable Court grant the request to stay litigation until further order of court. Respectfully submitted, JONES, GREGG, CREEHAN GERACE, LLP BY: JR., ESQUIRE Pix/Io uo-f 7,4906 {,Jones Gregg Creehan Gerace, LLP 411 Seventh Avenue, Suite 1200 Pittsburgh, PA 15219 (412) 261-6400 ATTORNEY FOR THE CLASS REPRESENTATIVES AND THE CLASS PLAINTIFFS IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, JAMES WOJCICKI, individually; PROVENTUS CIVIL DIVISION HOLDINGS, LLC, A Limited Liability Company; GALA LIMITED a Limited Partnership; and on behalf of themselves and all others similarly situated, G.D. 15-8738 Plaintiffs, v. PITTSBURGH WATER AND SEWER AUTHORITY, JORDAN TAX SERVICE, VEOLIA WATER NORTH AMERICA, Defendants. ORDER OF COURT AND NOW, this 2 day of Na 2016, it is hereby ORDERED, ADJUDGED, and DECREED that the above-referenced action is temporarily stayed pending settlement negotiations. The case will be placed back on the list for preliminary objections upon request of parties and further order of court. BY THE COURT: IW WV CERTIFICATE OF SERVICE The undersigned hereby certifies that true and correct copies of the foregoing . 74"? MOTION FOR STAY OF PROCEEDINGS was served this day of May, 2016, upon all counsel of record by Email Delivery, addressed as follows: Mark F. Nowak, Esquire ClarkHill, RC. One Oxford Centre 301 Grant Street, 14th Floor Pittsburgh, PA 15219-1425 (mnowak@clarkhill.com) Attorneys for Defendant The Pittsburgh Water and Sewer Authority Michael G. McCabe, Esquire Goehring, Rutter Boehm, PC Frick Building 437 Grant Street, 14th Floor Pittsburgh, PA 15219 (MMcCabe@grblaw.com) Attorneys for Jordan Tax Service Andrew K. Fletcher, Esquire Pepper Hamilton, LLP 500 Grant Street, Suite 5000 Pittsburgh, PA 15219 (fletchera@pepperlaw.com) Attorneys Water North America JONES, GREGG, CREEHAN 8: GERACE, LLP BY: ., ESQUIRE . ATTORNEY FOR THE CLASS REPRESENTATIVES AND THE CLASS PLAINTIFFS