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)

5

J. Andrew Coombs (SBN 123881)
[e-mail]
Nicole L. Drey (SBN 250235)
[e-mail]
J. Andrew Coombs, A Prof. Corp.
517 East Wilson Avenue, Suite 202
Glendale, California 91206
Telephone: [phone]
Facsimile: [phone]

6

Attorneys for Plaintiff DC Comics

7

Larry Zerner (SBN 155473)
[e-mail]
ZernerLaw
1801 Century Park East, Suite 2400
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]

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