DC Comics v. Mark Towle et al

Filing 9

Joint STIPULATION Extending Time to Answer the complaint as to Mark Towle answer now due 12/6/2011, filed by plaintiff DC Comics.(Drey, Nicole)

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5 J. Andrew Coombs (SBN 123881) andy@coombspc.com Nicole L. Drey (SBN 250235) nicole@coombspc.com J. Andrew Coombs, A Prof. Corp. 517 East Wilson Avenue, Suite 202 Glendale, California 91206 Telephone: (818) 500-3200 Facsimile: (818) 500-3201 6 Attorneys for Plaintiff DC Comics 7 Larry Zerner (SBN 155473) zernerlaw@gmail.com ZernerLaw 1801 Century Park East, Suite 2400 Los Angeles, California 90067 Telephone: (310) 773-3623 Facsimile: (310) 388-5624 1 2 3 4 8 9 10 11 12 Attorney for Defendant Mark Towle, An individual and d/b/a Gotham Garage 13 UNITED STATES DISTRICT COURT 14 CENTRAL DISTRICT OF CALIFORNIA 15 16 DC Comics, 17 18 19 20 21 Plaintiff, v. Mark Towle, an individual and d/b/a Gotham Garage, and Does 1 – 10, inclusive, Defendants. 22 23 24 25 ) ) Case No. CV11-3934 RSWL (OPx) ) ) STIPULATION TO EXTEND TIME ) TO RESPOND TO COMPLAINT ) ) ) ) ) ) ) ) PLAINTIFF DC Comics (“Plaintiff”), by and through its counsel of record, J. Andrew Coombs, of J. Andrew Coombs, A P.C., and Defendant Mark Towle, an individual and d/b/a Gotham Garage (“Defendant”), by and through his counsel of 26 27 record, Larry Zerner, hereby stipulate and agree as follows: 28 DC Comics v. Towle: Stip. to Extend Time -1- 1 WHEREAS the Complaint was filed in the above-captioned matter on or 2 3 about May 6, 2011; WHEREAS Plaintiff caused the Summons and Complaint to be served on the 4 5 Defendant via publication on or about October 7, 2011; 6 WHEREAS Defendant has raised certain issues, into which Plaintiff is 7 8 researching, which may require Plaintiff to amend its Complaint; 9 WHEREAS Plaintiff and Defendant are continuing to work towards resolution 10 11 of the claims alleged in the Complaint herein; WHEREAS providing Defendant additional time within which to move, plead 12 13 or otherwise respond to the Complaint will enable the Parties to resolve certain 14 15 issues regarding the Complaint and the claims alleged therein; WHEREAS Defendant proposes to move, plead or otherwise respond to the 16 17 Complaint in the event the Parties are unable to resolve this matter; and 18 19 20 21 /// /// /// 22 23 /// 24 /// 25 /// 26 27 /// 28 /// DC Comics v. Towle: Stip. to Extend Time -2- 1 NOW, THEREFORE, Plaintiff and Defendant stipulate and agree that 2 3 Defendant shall have through and until December 6, 2011, to respond to the 4 Complaint. 5 DATED: November 9, 2011 J. Andrew Coombs, A Professional Corp. 6 7 /s/ Nicole L. Drey By: __________________________________ J. Andrew Coombs Nicole L. Drey Attorneys for Plaintiff DC Comics 8 9 10 11 12 DATED: November 4, 2011 ZernerLaw 13 By: __________________________________ Larry Zerner Attorney for Defendant Mark Towle, an individual and d/b/a Gotham Garage 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DC Comics v. Towle: Stip. to Extend Time -3- PROOF OF SERVICE I, the undersigned, certify and declare that I am over the age of 18 years, employed in the County of Los Angeles, and not a party to the above-entitled cause. I am employed by a member of the Bar of the United States District Court of California. My business address is 517 East Wilson Avenue, Suite 202, Glendale, California 91206. On November 9, 2011, I served on the interested parties in this action with: STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT in support for the following civil action: Warner Bros. Entertainment Inc. v. M. Towle, et al. by placing a true copy thereof in an envelope to be immediately sealed thereafter. I am readily familiar with the office’s practice of collecting and processing correspondence for mailing. Under that practice it would be deposited with the United States Postal Service on the same day with postage thereon fully prepaid at Glendale, California in the ordinary course of business. I am aware that on motion of the party served, service presumed invalid if postal cancellation date or postage meter is more than one day after date of deposit for mailing in affidavit. Mark Towle d/b/a Gotham Garage 1601 W. MacArthur Blvd., #4-G Santa Ana, CA 92704 Larry Zerner Zerner Law 1801 Century Park East, Suite 2400 Los Angeles, CA 90067 Place of Mailing: Glendale, California Executed on November 9, 2011, at Glendale, California Katrina Bartolome