De Santos v. Jaco Oil Company

Filing 16

STIPULATION 15 and ORDER to Continue the Pleading Amendment Deadline, signed by Magistrate Judge Jennifer L. Thurston on 11/25/2014. (Hall, S)

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Ross E. Shanberg (SBN 179842)
Shane C. Stafford (SBN 216151)
Aaron A. Bartz (SBN 198722)
SHANBERG, STAFFORD & BARTZ, LLP
19200 Von Karman Avenue, Suite 400
Irvine, California 92612
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiff LINDA DE SANTOS
and all others similarly situated

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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LINDA DE SANTOS an individual, on
behalf of herself and all others
similarly situated,

CASE NO. 1:14-CV-00738-JLT
Assigned to Hon. Jennifer L. Thurston

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Plaintiff,
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vs.
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ACO OIL COMPANY, a California
corporation; and DOES 1 through 100,
inclusive,

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Defendants.
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JOINT STIPULATION TO
CONTINUE THE PLEADING
AMENDMENT DEADLINE;
ORDER;
DECLARATION OF SHANE C.
STAFFORD IN SUPPORT
THEREOF
(Doc. 15)

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JOINT STIPULATION TO CONTINUE PLEADING AMENDMENT DEADLINE; ORDER;
DECLARATION OF SHANE C. STAFFORD IN SUPPORT THEREOF

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Plaintiff, LINDA DE SANTOS and Defendant JACO OIL COMPANY
(“JACO”), by and through their attorneys of record, hereby stipulate as follows:
Whereas, Plaintiff has filed a class action based on Defendant JACO’s

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alleged violations of the Fair Credit Reporting Act, 15 U.S.C. § 1681, et seq.

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(“FCRA”), and the Investigative Consumer Reporting Agencies Act, California

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Civil Code § 1786, et seq. (“ICRAA”);

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Whereas, the Court issued its Amended Scheduling Order on August 27,

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2014, ordering that all pleading amendments be filed no later than February 13,

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2015;
Whereas, on October 28, 2014, Plaintiff propounded Special Interrogatories

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and Requests for Production of Documents on Defendant JACO to investigate her
claims regarding Defendant’s unlawful practices;
Whereas, Defendant JACO’s responses to Plaintiff’s discovery were due on

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or before December 1, 2014;
Whereas, the parties agreed to a 30-day extension of time for Defendant
JACO to respond to Plaintiff’s discovery, which will now be due on or before
December 31, 2014;

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Whereas, the parties further agreed to a 60-day extension of time for the
parties to file pleading amendments, from February 13, 2015 to April 13, 2015, in
the event Plaintiff uncovers additional entities that should be named as defendants
in this matter.
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-2JOINT STIPULATION TO CONTINUE PLEADING AMENDMENT DEADLINE; ORDER;
DECLARATION OF SHANE C. STAFFORD IN SUPPORT THEREOF

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IT IS THEREFORE STIPULATED THAT the cutoff for the parties to

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file pleading amendments be continued 60-days from February 13, 2015 to April

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13, 2015.

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DATED: November 25, 2014

SHANBERG STAFFORD & BARTZ LLP

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By:

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/s/ Shane C. Stafford
SHANE C. STAFFORD
ROSS E. SHANBERG
AARON A. BARTZ
Attorneys for Plaintiff
LINDA DE SANTOS,
and all others similarly situated

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DATED: November 25, 2014

KLEIN, DENATALE, GOLDNER,
COOPER, ROSENLIEB & KIMBALL LLP

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By:

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/s/ Connie M. Parker
David J. Cooper
Connie M. Parker
Attorneys for Defendant
JACO OIL COMPANY

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-3JOINT STIPULATION TO CONTINUE PLEADING AMENDMENT DEADLINE; ORDER;
DECLARATION OF SHANE C. STAFFORD IN SUPPORT THEREOF

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ORDER
Pursuant to the Stipulation of the parties, and for good cause shown, the
Court ORDERS:
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The scheduling order (Doc. 12) is amended to extend the pleading

amendment deadline to April 13, 2015;

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2.

No other amendments, including the deadline to complete discovery,

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are authorized.

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IT IS SO ORDERED.
Dated:

November 25, 2014

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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-4JOINT STIPULATION TO CONTINUE PLEADING AMENDMENT DEADLINE; ORDER;
DECLARATION OF SHANE C. STAFFORD IN SUPPORT THEREOF