Kerkorian v. Samsung Electronics America, Inc.

Filing 12

JOINT STIPULATION ADN ORDER TO EXTEND TIME TO RESPOND TO FIRST AMENDED COMPLAINT. (Doc. 11) Defendant Samsung Electronics America, Inc. is HEREBY GRANTED an extension of time of an additional twenty-eight (28) days, up to and including August 28, 2018, to respond to the First Amended Complaint in this action. Order signed by Magistrate Judge Sheila K. Oberto on 8/2/2018. (Timken, A)

1 Michael D. Adams (State Bar No. 185835)

[e-mail]

2 Brian C. Berggren (State Bar No. 279279)

[e-mail]

3 Danielle Serbin (State Bar No. 294369)

[e-mail]

4 RUTAN & TUCKER, LLP

611 Anton Boulevard, Suite 1400

5 Costa Mesa, California 92626-1931

Telephone: [phone]

6 Facsimile: 714-546-9035
7 Attorneys for Defendant

SAMSUNG ELECTRONICA AMERICA, INC.

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9

UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

12 PAUL KERKORIAN, an individual, on

behalf of himself and all other similarly
13 situated,
Plaintiff,

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15

v.

Case No. 1:18-cv-00870-DAD-SKO
JOINT STIPULATION AND ORDER
TO EXTEND TIME TO RESPOND
TO FIRST AMENDED COMPLAINT
(Doc. 11)

16 SAMSUNG ELECTRONICS

AMERICA, INC., a New Jersey

17 corporation, and DOES 1 through 25,

inclusive,

18

Defendant.

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21

This Joint Stipulation to Extend Time to Respond to First Amended

22 Complaint is entered into by and between, on the one hand, Plaintiff Paul Kerkorian
23 (“Plaintiff”), and, on the other hand, Defendant Samsung Electronics America, Inc.
24 (“Defendant”).
25

RECITALS

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WHEREAS, Plaintiff filed his Complaint on June 22, 2018 (Dkt. No. 2);

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WHEREAS, Plaintiff filed his First Amended Complaint (“FAC”) on July 3,

28
-12861/099999-0084
12664071.1 a08/02/18

JOINT STIPULATION TO EXTEND TIME TO RESPOND TO FIRST
AMENDED COMPLAINT

1 2018 (Dkt. No. 8);
2

WHEREAS, Plaintiff personally served the FAC on Samsung on July 10,

3 2018 (See Dkt. No. 9);
4

WHEREAS, pursuant to Rule 15(a)(3) of the Federal Rules of Civil

5 Procedure, Defendant’s time to answer or otherwise respond to the FAC is presently
6 July 31, 2018;
7

WHEREAS, Defendant has requested and Plaintiff has consented to an

8 additional 28 days for Defendant to answer or otherwise respond to the FAC;
9

WHEREAS, an additional 28 days for Defendant to answer or otherwise

10 respond to the FAC will not alter the date of any event or any deadline already fixed
11 by Court order;
12

WHEREAS, Defendant has not previously requested any extension of time in

13 this case;

STIPULATION

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15

BASED UPON THE FOREGOING, THE PARTIES HEREBY STIPULATE

16 AND AGREE AS FOLLOWS:
17

The deadline for Defendant to answer or otherwise respond to the First

18 Amended Complaint in this matter shall be extended by twenty-eight (28) days,
19 from July 31, 2018 to August 28, 2018.
20 Dated: August 2, 2018
21

RUTAN & TUCKER, LLP
MICHAEL D. ADAMS
BRIAN C. BERGGREN
DANIELLE SERBIN

22

By: /s/ Michael Adams
Michael D. Adams
Attorneys for Defendant
SAMSUNG ELECTRONICA
AMERICA, INC.

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-22861/099999-0084
12664071.1 a08/02/18

JOINT STIPULATION TO EXTEND TIME TO RESPOND TO FIRST
AMENDED COMPLAINT

1 Dated: August 2, 2018
2

WEBB LAW GROUP, APC
LENDEN F. WEBB
CHRISTOPHER E. NICHOLS

3

By: /s/ Christopher E. Nichols
Christopher E. Nichols
Attorneys for Plaintiff
PAUL KERKORIAN

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9

ORDER

10

Upon consideration of the parties’ Joint Stipulation to Extend Time to Respond

11

12 to First Amended Complaint (Doc. 11), and pursuant Local Rule 144(a), Defendant
13 Samsung Electronics America, Inc. is HEREBY GRANTED an extension of time of
14 an additional twenty-eight (28) days, up to and including August 28, 2018, to respond
15 to the First Amended Complaint in this action.
16
17 IT IS SO ORDERED.
18

Dated:

August 2, 2018

19

/s/

Sheila K. Oberto

UNITED STATES MAGISTRATE JUDGE

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-32861/099999-0084
12664071.1 a08/02/18

JOINT STIPULATION TO EXTEND TIME TO RESPOND TO FIRST
AMENDED COMPLAINT

.