Abrahamson et al v. Berkley

Filing 36

STIPULATION Extending Time to File an Answer to First Amended Complaint by Not more than 28 days; ORDER - Defendants deadline to file his Answer to Plaintiffs First Amended Complaint is extended to September 22, 2016. signed by Magistrate Judge Barbara A. McAuliffe on 9/16/2016. (Herman, H)

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Jeffrey D. Polsky (SBN 120975)
[e-mail]
Jaemin Chang (SBN 232612)
[e-mail]
FOX ROTHSCHILD LLP
345 California Street, Suite 2200
San Francisco, CA 94104
Telephone: [phone]
Facsimile: 415.391.4436
Attorneys Defendant
BRAD BERKLEY

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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GLENN A. ABRAHAMSON, an individual;
JOSEPH WONG, an individual; BB17, LLC,
a Wyoming limited liability company,

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Plaintiffs,
vs.

Case No.: 1:16-CV-00348-AWI-BAM
STIPULATION EXTENDING TIME TO
FILE AN ANSWER TO FIRST
AMENDED COMPLAINT BY NOT
MORE THAN 28 DAYS; [PROPOSED]
ORDER

BRAD BERKLEY, an individual,
First Amended Complaint Filed:

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3/18/16

Defendant.

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Plaintiffs Glenn A. Abrahamson ("Plaintiff") and Defendant Bradley Berkley ("Defendant"),

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by and through their attorneys of record in this case, hereby stipulate and agree that:
WHEREAS, Plaintiffs filed their initial Complaint in this action on March 11, 2016 (ECF

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No. 1);

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WHEREAS, Plaintiffs filed their First Amended Complaint on March 18, 2016 (ECF No. 2);

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WHEREAS, Defendant's deadline to file a responsive pleading was extended by 14 days to

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May 6, 2016;
WHEREAS, Defendant filed its Motion to Dismiss for Lack of Personal Jurisdiction and an
anti-SLAPP Motion to Strike on May 6, 2016;
STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT
ACTIVE 42266651V2

CASE NO. 1:16-CV-00348-AWI-BAM

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WHEREAS, the Court issued and entered its ruling on the Motion to Dismiss and Motion to
Strike on September 2, 2016;
WHEREAS, the current deadline to file an Answer to the First Amended Complaint is
September 16, 2016;
WHEREAS, the parties' respective attorneys met and conferred pursuant to Rule 26(f) and

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agree to allow Defendant a brief 6-day extension of time to file his Answer (the two extensions will

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be less than 28 days prescribed in Rule 144(a)); and

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WHEREAS, the joint discovery plan submittal deadline and the Mandatory Scheduling
Conference date will not be changed.
NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties, through
their respective counsel, that Defendant shall file his Answer by September 22, 2016.
IT IS SO STIPULATED.
Dated: Septmeber 15, 2016

FOX ROTHSCHILD LLP

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By

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Dated: Septmeber 15, 2016

/s/Jaemin Chang
Jeffrey D. Polsky
Jaemin Chang
Attorneys for Defendant
BRAD BERKLEY
KAHN, SOARES & CONWAY, LLP

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By

/s/ Richard C. Conway (as authorized on 9/14/16)
Richard C. Conway
Attorneys for Plaintiff
GLENN A. ABRAHAMSON

ORDER

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The Court, having duly considered the parties’ stipulation set forth above, and good cause

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appearing, orders as follows:
Defendant’s deadline to file his Answer to Plaintiffs’ First Amended Complaint is extended

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to September 22, 2016.

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IT IS SO ORDERED.

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Dated:

September 16, 2016

/s/ Barbara

A. McAuliffe

UNITED STATES MAGISTRATE JUDGE
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