Garfil v. Dell Financial Services, LLC

Filing 18

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr., on 12/19/14 ORDERING that Defendant shall have to and including 1/30/15, to move, answer, or otherwise respond to Plaintiff's Complaint. (Kastilahn, A)

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C. Brandon Wisoff (State Bar No. 121930)
[e-mail]
Alexander M. Porcaro (State Bar No. 281185)
[e-mail]
Farella Braun + Martel LLP
235 Montgomery Street, 17th Floor
San Francisco, CA 94104
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
DELL FINANCIAL SERVICES, LLC

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UNITED STATES DISTRICT COURT OF CALIFORNIA

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EASTERN DISTRICT

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FLOSERFIDA GARFIL,

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Case No. 14-cv-01729-GEB-AC

Plaintiff,

STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME TO
RESPOND TO COMPLAINT (L.R. 144)

v.
DELL FINANCIAL SERVICES, LLC,
foreign limited liability company; and DOES
1 to 10, inclusive,

Complaint filed:
Complaint served:
Current response date:
New response date:

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Defendants.

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July 22, 2014
August 11, 2014
December 31, 2014
January 30, 2015

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Plaintiff FLOSERFIDA GARFIL (“Plaintiff”) and Defendant DELL FINANCIAL

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SERVICES, LLC (“Defendant”), by and through their respective counsel, hereby stipulate and

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agree as follows:

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WHEREAS, on July 22, 2014, Plaintiff filed her Complaint in this action;

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WHEREAS, on August 11, 2014, Plaintiff served Defendant with a copy of the Complaint

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and Summons in a Civil Action;
WHEREAS, pursuant to Federal Rule of Civil Procedure 12(a), Defendant initially needed
to file and serve a response to Plaintiff’s Complaint on or before September 2, 2014;

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STIPULATION & ORDER TO EXTEND
TIME TO RESPOND TO COMPLAINT
Case No. 14-cv-01729-GEB-AC

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30674\4690292.1

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WHEREAS, pursuant to stipulation filed on August 22, 2014, the parties extended the
time for Defendant’s response by 28 days, to and including September 30, 2014, as authorized by
Local Rule 144 without Court order;
WHEREAS, pursuant to stipulation and Court order entered on September 24, 2014, the
time for Defendant’s response was further extended to October 31, 2014;
WHEREAS, pursuant to stipulation and Court order entered on October 23, 2014, the time
for Defendant’s response was further extended to December 31, 2014;
WHEREAS, the parties are engaged in settlement discussions and wish to continue those
discussions before Defendant must prepare and file a response to Plaintiff’s Complaint;
WHEREAS, the parties also are discussing amending the pleadings and possible
arbitration if this matter should not settle;
WHEREAS both parties have agreed that good cause exists to extend the time for
Defendant to respond to Plaintiff’s Complaint to and including January 30, 2015;
NOW, THEREFORE, THE PARTIES HEREBY AGREE AND STIPULATE THAT
Defendant shall have to and including January 30, 2015, to move, answer, or otherwise respond to
Plaintiff’s Complaint.
IT IS SO STIPULATED.

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Dated: December 19, 2014

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FARELLA BRAUN + MARTEL LLP
By: /s/ Alexander M. Porcaro
Alexander M. Porcaro

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Attorneys for Defendant
DELL FINANCIAL SERVICES, LLC

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Dated: December 19, 2014

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PRICE LAW GROUP, APC
By: /s/ Stuart M. Price (as authorized on Dec. 19, 2014)
Stuart M. Price

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Attorneys for Plaintiff
FLOSERFIDA GARFIL

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STIPULATION & ORDER TO EXTEND
TIME TO RESPOND TO COMPLAINT
Case No. 14-cv-01729-GEB-AC

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30674\4690292.1

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[PROPOSED] ORDER
IT IS SO ORDERED.

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Dated: December 19, 2014

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STIPULATION & ORDER TO EXTEND
TIME TO RESPOND TO COMPLAINT
Case No. 14-cv-01729-GEB-AC

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30674\4690292.1