Southern California Institute of Law v. TCS Education System et al

Filing 31

Joint STIPULATION for Extension of Time to Amend Order on Motion to Dismiss Case,,,,,, 23 filed by plaintiff Southern California Institute of Law. (Attachments: # 1 Declaration, # 2 Proposed Order)(Shohet, George)

George A. Shohet SBN 112691
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LAW OFFICES OF GEORGE A. SHOHET,
A PROFESSIONAL CORPORATION

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245 Main Street, Suite 310

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Venice, CA9029l-5216
Tel.: [phone]
Fax: (3Iq 452-2270

fAdditional Counsel Appear on Signature Page]

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Attomeys for Plaintiff
Southern Califomia Institute of Law

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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SOUTHERN CALIFORNIA
INSTITUTE OF LAW, a California
corporation,

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Plaintiff'
vs.

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TCS EDUCATION SYSTEM, an

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Illinois corporation; DAVID J.
FIGULI, an individual; and GLOBAL
EQUITIES, LTD. dlbla HIGHER
EDUCATION GROUP, a Colorado
limited liability company,

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CASE NO,: CVl0-8026 PSG (AJWx)
fAssigned to Hon. Philip S. Gutierrez]
STIPULATION EXTENDTNG THE
TIME FOR PLAINTIFF TO FILE

FIRST AMENDED COMPLAINT
Action Filed: Oct. 25,2010
Current Filing Date: April 26,2011
Proposed Filing Date: May 17 ,2011
Courtroom: 880
[Proposed Order lodged concurrently
herewith and Supporting Declaration
fi led concurrently herewithl

Defendants.
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STIPT,ILATION EXTBNDING THE TIME FOR PLAINTIFF TO FILE ITS FIRST AMENDED COMPLAINT

WHEREAS, on April 4,201

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the Court granted in part and denied in part

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defendant TCS Education System's Motion to Dismiss the Complaint filed by

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plaintiff Southem California Institute of Law; and
WHEREAS, the Court granted the plaintiff until April 26,201I to file its

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First Amended Complaint; and

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WI{EREAS, defendants David J. Figuli ("Figuli") and Global Equities, LLC

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("Global") have requested time to retain local counsel and further discuss the case

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with plaintiffs counsel before the First Amended Complaint is filed in an effort to

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reach a resolution; and

WHEREAS, all parties arc agreeable to extending the time for the filing of

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the First Amended Complaint;

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED,

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subject to the approval of the Court, by and between counsel for the undersigned

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parties, and defendants Figuli and Global, that the time for plaintiff to file its First

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Amended Complaint is hereby extended from April26,2Al1, to and including,

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May 17,2011.

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IT IS SO STIPULATEDI

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Jeffrey Stewart Whittington
KAUFMAN BORGEEST AND RYAN

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LLP

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23975 Park Sorrento
Suite 370

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Calabasas,CAgi302

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8-880-0992
Fax: I18-880-0993
Email : j whittington()kbrlaw. com
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Dated:

April /7 ,2011

{')r*r, /ilr4,,

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By

Attfrneys for Defen dant
TCS Education System

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STIPULATION EXTENDING ]'HE'TIME FOR PLAINTIFF TO FILE ITS FIRST AMilNDED COMPLAINT

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DAVID J. FIGULI
GLOBAL ilQUITIES, LLC

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8697 S. Blue Creek Road
Evergreen, CO 8043q
Tel.:[phone]

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Dated: April 22,2011

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By
David J. Figuli, Esq. for himself and
Global Equities, LLC
In Pro Per

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LAW OFFICES GF GEORGE A. SHOHET

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Gretchen M. Nelson SBN 112566

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KT.EINT}LER & KREINDLER LLP
707 Wilshire Blvd, Suite 4100
Los Angeles, CA 90017

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Tel.:{2i3) 622-646q

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Fax: [phone]

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Dated: April

/(rort

By
George A. Shohet

Attorneys for Plaintiff
Southem California Institute of Law

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StiFulauox nxronliNC rnr rrME

FoR pLAINTIFF To FILE ITs FIRsr AMENDED COMPLAINI'

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CERTIFICATE OF SERVICE
The undersigned hereby certifies that all counsel of record who have

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consented to electronic service are being served with a copy of the foregoing

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document via Central District of California CMIF.CF system on April 22,2011

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/s/ Georee A. Shohet

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CERTIFICATE OF SERVICE