Baja Insurance Services, Inc. v. Shanze Enterprises, Inc.

Filing 54

STIPULATION TO EXTEND TIME and ORDER signed by District Judge Kimberly J. Mueller on 4/14/16. Plaintiff shall file its Second-Amended Complaint on or before 4/28/16; Defendant Plano Insurance Group, Inc. shall file its counterclaim on or before 4/ 28/16; Defendant shall file its answer or other responsive pleading within 21 days of receipt of the Summons and Second- Amended Complaint; and Plaintiff shall file its responsive pleading within 21 days of the filing of counterclaim.(Mena-Sanchez, L)

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Salar Atrizadeh, Esq. (SBN: 255659)
LAW OFFICES OF SALAR ATRIZADEH
9701 Wilshire Blvd., 10th Floor
Beverly Hills, CA 90212
Telephone: [phone]
Facsimile: 310-694-3057
Email: [e-mail]

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Attorneys for Plaintiff
BAJA INSURANCE SERVICES, INC.
Francis Torrence, Esq. (SBN: 154653)
WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP
525 Market Street, 17th Floor
San Francisco, CA 94105-2725
Telephone: [phone]
Facsimile: 415-434-1370
Email: [e-mail]
Attorneys for Defendant
PLANO INSURANCE GROUP, INC., f/k/a SHANZE
ENTERPRISES, INC., f/d/b/a BAJA AUTO INSURANCE

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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BAJA INSURANCE SERVICES, INC., a
California corporation,

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Case No.: 2:14-cv-02423-KJM-AC

Plaintiff,
JOINT STIPULATION TO EXTEND
TIME AND ORDER

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v.
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SHANZE ENTERPRISES, INC. d/b/a
BAJA AUTO INSURANCE, and DOES 1
to 10,
Defendants.

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_____________________________________________________________________________
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JOINT STIPULATION TO EXTEND TIME AND ORDER]

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TO THE UNITED STATES DISTRICT COURT, ALL INTERESTED PARTIES, AND

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THEIR ATTORNEYS:

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Pursuant to the Court’s Order, under Dkt. No. 50, Plaintiff and Defendant hereby enter
into this stipulation and request that the Court permit the parties to file their respective

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pleadings as follows:
1. Plaintiff shall file its Second-Amended Complaint on or before April 28, 2016;
2. Defendant Plano Insurance Group, Inc. shall file its counterclaim on or before April 28,
2016;
3. Defendant shall file its answer or other responsive pleading within 21 days of receipt of
the Summons and Second-Amended Complaint; and
4. Plaintiff shall file its responsive pleading within 21 days of the filing of counterclaim.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Dated: April 8, 2016

LAW OFFICES OF SALAR ATRIZADEH

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By:

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/s/ Salar Atrizadeh
SALAR ATRIZADEH, ESQ.
Attorneys for Plaintiff
BAJA INSURANCE SERVICES, INC.

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Dated: April 8, 2016

WILSON ELSER MOSKOWITZ EDELMAN &
DICKER, LLP

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By:
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/s/ Francis Torrence
FRANCIS TORRENCE, ESQ.
Attorneys for Defendant
PLANO INSURANCE GROUP, INC.

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IT IS SO ORDERED, PURSUANT TO STIPULATION.

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DATED: April 14, 2016

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UNITED STATES DISTRICT JUDGE

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_____________________________________________________________________________
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JOINT STIPULATION TO EXTEND TIME AND ORDER]