Willis v. Enterprise Drilling Fluids, Inc. et al

Filing 11

STIPULATION and ORDER to Extend Time to File First Responsive Pleading to Class Action Complaint re 10 , signed by Magistrate Judge Jennifer L. Thurston on 6/23/2015. (Hall, S)

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SEYFARTH SHAW LLP
Christian J. Rowley (SBN 187293)
[e-mail]
Kerry M. Friedrichs (SBN 198143)
[e-mail]
560 Mission Street, 31st Floor
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]

THE BLANCHARD LAW GROUP, APC
Lonnie C. Blanchard, III (SBN 93530)
[e-mail]
3311 East Pico Boulevard
Los Angeles, California 90023
Telephone [phone]
Facsimile: [phone]

SEYFARTH SHAW LLP
Sophia S. Kwan (SBN 257666)
[e-mail]
400 Capitol Mall, Suite 2350
Sacramento, CA 95814
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants
Berry Petroleum Company, LLC and
Linn Operating, Inc.

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THE DION-KINDEM LAW FIRM
Peter R. Dion-Kindem, P.C.
Peter R. Dion-Kindem (SBN 95267)
[e-mail]
21550 Oxnard Street, Suite 900
Woodland Hills, California 91367
Telephone: [phone]
Facsimile: [phone]

HOLMES LAW GROUP, APC
Jeffrey D. Holmes (SBN 100891)
[e-mail]
3311 East Pico Boulevard
Los Angeles, California 90023
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff Kenneth Willis
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Kenneth Willis, an individual, on behalf of himself
and all others similarly situated,

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Plaintiffs,
v.
Enterprise Drilling Fluids, Inc., Berry Petroleum
Company, LLC, Linn Operating, Inc., and DOES 1
through 10,

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Case No. 1:15-cv-00688 --- JLT
SECOND STIPULATION TO EXTEND
TIME TO FILE FIRST RESPONSIVE
PLEADING TO CLASS ACTION
COMPLAINT AND [PROPOSED] ORDER
(Doc. 10)

Defendants.
Pursuant to L.R. 144(a), Plaintiff KENNETH WILLIS, individually and on behalf of others
similarly situated, and Defendants BERRY PETROLEUM COMPANY, LLC, and LINN OPERATING,
INC. (“Defendants”) (collectively “the Parties”), by and through their undersigned counsel, hereby
stipulate and agree as follows:
WHEREAS, Plaintiff’s Class Action Complaint was filed on May 5, 2015;

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SECOND STIPULATION TO EXTEND TIME TO FILE FIRST RESPONSIVE PLEADING TO COMPLAINT AND
[PROPOSED] ORDER
20198164v.1

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WHEREAS, Defendants were served with the Class Action Complaint on May 13, 2015;

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WHEREAS, Defendants’ deadline to file a first responsive pleading is June 3, 2015;

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WHEREAS, on May 29, 2015 the Parties stipulated and agreed to a 21-day time extension for

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Defendants to file a responsive pleading to the Class Action Complaint, up to and including June 24,

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2015;

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WHEREAS, on June 22, 2015, the Parties stipulated and agreed to a 7-day time extension for

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Defendants to file a responsive pleading to the Class Action Complaint, up to and including July 1,

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2015;

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WHEREAS, the Parties have not stipulated to extend the time for Defendants to file a responsive
pleading to the Class Action Complaint by more than 28 days as permitted under L.R. 144(a);
IT IS SO STIPULATED that the Parties agree to a 7-day extension of time for Defendants to

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file a responsive pleading to the Class Action Complaint, up to and including July 1, 2015. The Parties

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further agree that this extension will not alter the date of any event or any deadline already fixed by

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Court Order including, but not limited to, the August 19, 2015 Scheduling Conference. By signing this

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stipulation, the parties have not waived any rights or defenses with respect to any potential issue in this

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litigation, including but not limited to, the assertion of jurisdictional and any other defenses, either by

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motion or otherwise.

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Dated: June 22, 2015

SEYFARTH SHAW LLP

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By:

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/s Christian J. Rowley
Christian J. Rowley
Kerry M. Friedrichs
Sophia S. Kwan

Attorneys for Defendants
Berry Petroleum Company, LLC and
Linn Operating, Inc.

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SECOND STIPULATION TO EXTEND TIME TO FILE FIRST RESPONSIVE PLEADING TO COMPLAINT AND
[PROPOSED] ORDER
20198164v.1

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Dated: June 22, 2015

THE DION-KINDEM LAW FIRM

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By:
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/s Peter R. Dion-Kindem
Peter R. Dion-Kindem, P.C.
Peter R. Dion-Kindem
Attorneys for Plaintiff Kenneth Willis

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ORDER
The Court, having reviewed the Parties’ Second Stipulation to Extend Time to Respond to the
Complaint, and finding GOOD CAUSE appearing therefor, hereby GRANTS the Parties’ stipulated

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request, and hereby extends Defendants’ deadline to file a first responsive pleading from June 24, 2015

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to July 1, 2015.

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Absolutely no further requests for extensions of time to file the responsive pleading will be
considered.

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IT IS SO ORDERED.
Dated:

June 23, 2015

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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SECOND STIPULATION TO EXTEND TIME TO FILE FIRST RESPONSIVE PLEADING TO COMPLAINT AND
[PROPOSED] ORDER
20198164v.1