Khatkar v. Collecto Inc.

Filing 7

Second STIPULATION to Extend Time to Respond to Complaint; ORDER the Parties stipulate and agree that Defendant shall have an extension of time up to and including January 31, 2017 within which to respond to Plaintiff' Complaint. signed by Magistrate Judge Barbara A. McAuliffe on 1/18/2017. (Herman, H)

1 Lee Paul Mankin, IV

[e-mail]

2 LAW OFFICE OF L. PAUL MANKIN IV

4655 Cass Street

3 Suite 112

San Diego, CA 92109

4 Tel: [phone]
5 Fax: [phone]

6 Attorney for Plaintiff

SANDIE KHATKAR

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David J. Kaminski (SBN 128509)
[e-mail]
Shawn Eldridge (276581)
[e-mail]
CARLSON & MESSER LLP
5959 West Century Boulevard, Suite 1214
Los Angeles, CA 90045
[phone] Telephone
[phone] Facsimile

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Attorneys for Defendant
13 COLLECTO INC., dba EOS, CCA
UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA

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SANDIE KHATKAR,

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Plaintiff,

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vs.

19 COLLECTO, INC. dba EOS CCA,
and DOES 1-10, inclusive,
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Defendant.

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Case No. 1:16-cv-01888-LJO-BAM
SECOND STIPULATION TO EXTEND
TIME TO RESPOND TO COMPLAINT;
ORDER
Complaint Removed: December 19, 2016
Current Response Due:
January 17, 2017
New Response Deadline: January 31, 2017

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IT IS HEREBY STIPULATED between Plaintiff SANDIE KHATKAR

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24 (“Plaintiffs”) and Defendants COLLECTO INC., dba EOS, CCA (“Defendant”), through
25 their respective counsel, as follows:

WHEREAS, Defendant removed the Complaint on December 19, 2016;

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WHEREAS, a Stipulation to Extend Time to Answer was filed on December 21,

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2 2016, extending the deadline for Defendant to respond to January 17, 2017 [ Docket No.
3 5];
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WHEREAS, Defendant, due to the press of business, needs additional time to

5 review documents to assist in an early resolution of the entire matter;
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WHEREAS, Plaintiff and Defendant (hereinafter referred to as “Parties”) have met

7 and conferred and agree good cause exists to extend the deadline for Defendant to
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respond to Plaintiff’s Complaint to January 31, 2017;

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WHEREAS, no party claims prejudice as a result of the extension of time;

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WHEREFORE, the Parties stipulate and agree that Defendant shall have an
extension of time up to and including January 31, 2017 within which to respond to
Plaintiff’s Complaint.

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LAW OFFICE OF L. PAUL MANKIN
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Dated: January 17, 2017
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By: /s/ L. Paul Mankin
L. Paul Mankin
Attorney for Plaintiff
SANDIE KHATKAR

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Dated: January 17, 2017

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CARLSON & MESSER, LLP
By: /s/ Shawn Eldridge
David J. Kaminski
Shawn Eldridge
Attorneys for Defendant
COLLECTO INC. dba EOS, CCA

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ORDER

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IT IS SO ORDERED THAT the Parties stipulate and agree that Defendant shall have an

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24 extension of time up to and including January 31, 2017 within which to respond to Plaintiff’s Complaint.
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Dated: January 18, 2017

/s/ Barbara

A. McAuliffe

UNITED STATES MAGISTRATE JUDGE

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{