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)

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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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2.

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