Garfil v. Dell Financial Services, LLC

Filing 9

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr on 9/23/14 ORDERING Defendant shall have an additional 31 days, to and including 10/31/14, to move, answer, or otherwise respond to Plaintiff's Complaint. (Becknal, R)

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1 2 3 4 5 6 7 C. Brandon Wisoff (State Bar No. 121930) bwisoff@fbm.com Alexander M. Porcaro (State Bar No. 281185) aporcaro@fbm.com Farella Braun + Martel LLP 235 Montgomery Street, 17th Floor San Francisco, CA 94104 Telephone: (415) 954-4400 Facsimile: (415) 954-4480 Attorneys for Defendant DELL FINANCIAL SERVICES, LLC 8 9 UNITED STATES DISTRICT COURT OF CALIFORNIA 10 EASTERN DISTRICT 11 12 FLOSERFIDA GARFIL, 13 14 15 16 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: 17 Defendants. 18 July 22, 2014 August 11, 2014 September 30, 2014 October 31, 2014 19 20 Plaintiff FLOSERFIDA GARFIL (“Plaintiff”) and Defendant DELL FINANCIAL 21 SERVICES, LLC (“Defendant”), by and through their respective counsel, hereby stipulate and 22 agree as follows: 23 WHEREAS, on July 22, 2014, Plaintiff filed her Complaint in this action; 24 WHEREAS, on August 11, 2014, Plaintiff served Defendant with a copy of the Complaint 25 26 27 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; 28 STIPULATION & ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT Case No. 14-cv-01729-GEB-AC -1- 30674\4563410.1 1 2 3 4 5 6 7 8 9 10 11 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, Defendant has requested from Plaintiff additional time to conduct an initial factual investigation and prepare a response to Plaintiff’s Complaint; WHEREAS both parties have agreed that good cause exists to extend the time for Defendant to respond to Plaintiff’s Complaint by 31 days, to and including October 31, 2014; NOW, THEREFORE, THE PARTIES HEREBY AGREE AND STIPULATE THAT Defendant shall have an additional 31 days, to and including October 31, 2014, to move, answer, or otherwise respond to Plaintiff’s Complaint. IT IS SO STIPULATED. 12 13 14 Dated: September 19, 2014 15 FARELLA BRAUN + MARTEL LLP By: /s/ Alexander M. Porcaro Alexander M. Porcaro 16 Attorneys for Defendant DELL FINANCIAL SERVICES, LLC 17 18 19 Dated: September 19, 2014 20 PRICE LAW GROUP, APC By: /s/ Stuart M. Price (as authorized on Sept. 19, 2014) Stuart M. Price 21 Attorneys for Plaintiff FLOSERFIDA GARFIL 22 23 24 25 26 27 28 STIPULATION & ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT Case No. 14-cv-01729-GEB-AC -2- 30674\4563410.1 1 2 ORDER IT IS SO ORDERED. 3 4 Dated: September 23, 2014 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION & ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT Case No. 14-cv-01729-GEB-AC -3- 30674\4563410.1

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