Southern California Institute of Law v. TCS Education System et al
Filing
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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)
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George A. Shohet SBN 11269l
LAW OFFICES OF GEORGE A. SHOHET,
A PROFBSSIONAL CORPORATION
245 Main Street, Suite 310
Venice, CA9029I-5216
Tel.: (310) 4s2-3176
Fax: (3l0) 452-2270
fAdditional Counsel Appear on Signature Page of Stipulation]
Attorneys for Plaintiff
Southern California Institute of Law
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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SOUTHE,RN CALIFORNIA
INSTITUTE OF LAW, a California
corporation,
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Plaintiff,
VS.
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TCS EDUCATION SYSTEM, an
Illinois corporation; DAVID J.
FIGULI, an individual; and GLOBAL
EQUITIES, LTD. dlbla HIGHER
EDUCATION GROUP, a Colorado
limited liability company,
Defendants.
CASE NO.: CVl0-8026 PSG (AJWx)
[Assigned to Hon. Philip S. Gutienez]
DECLARATION OF GBORGE A.
SHOHET IN SUPPORT OF
STIPULATTON AND IPROPOSED]
ORDER TO EXTEND THE TIME
FOR PLAINTIFF TO FILE ITS FIRST
AMENDED COMPLAINT
Action Filed: Oct. 25, 2010
Current Filing Date: April 26,2011
Proposed Filing Date: May 17,201L
Courtroom: 880
fProposed Order lodged concurrently
herewith and Stipulation filed
concuffently herewith]
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DECLARATION OF GEORGE A. SHOHET IN SUPPORT OF STIPULATION AND IPROPOSEDI ORDER TO
EXTEND THE TIME FOR PLAINTIFF TO FILE ITS FIRST AMENDED COMPLAINT
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I, George A. Shohet, declare:
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I am an attorney licensed to practice in the courts of California and
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member of the Bar of this Court. I make this declaration in support of the parties'
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request for an extension of time to file plaintiffs First Amended Complaint, which
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is presently due to be filed on
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facts set forth herein and,
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testify about them.
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April 26,2011. I have personal knowledge of the
if called as a witness, could
and would competently
On April 2I,2011, Tom W. Armour, Esq., a Colorado attorney,
contacted me on behalf of defendants David J. Figuli and Global Equities, LLC.
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("Global"). Mr. Armour explained that Mr. Figuli and Global were seeking local
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representation. In addition, Mr. Armour explained that Mr. Figuli and Global
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wanted to discuss the claims against them in this case before plaintiff filed a First
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Amended Complaint. I told Mr. Armour that the plaintiff was agreeable to doing
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so as long as an extension was acceptable to TCS Education System ("TCS") and
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the Court was willing to permit an extension of time. I then spoke with Jeff
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Whittington, Esq., counsel for TCS, who, on April 22,2071, advised me that he
had approval from his client. The parties agreed to a three week extension of time
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to, and including, May 17,201I.
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The request for an extension of time is being made for good cause and
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not to delay the proceedings. Accordingly, the parties respectfully request that the
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Court grant the requested extension of time to file plaintiffs First Amended
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Complaint.
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I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct. Executed this *& auy of April at
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Los Angeles, California
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George A. Shohet
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NNCT,,AruTTON OF GEORGE A. SHOHET IN SUPPORT OF STIPULATION AND IPROPOSED] ORDER TO
EXTEND THE TIME FOR PLAINTIFF TO FILE TTS FIRST AMENDED COMPLAINT
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that all counsel of record who have
consented to electronic service are being served with a copy of the foregoing
document via Central District of California CM/ECF system on April 22,2011
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/s/ Georee A. Shohet
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CERTIFICATE OF' SERVICE
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