Castillo v. ADT, LLC

Filing 13

STIPULATION and ORDER 12 signed by Senior Judge William B. Shubb on 4/7/2015 extending time for defendant to amend answer to plaintiff's complaint to 4/24/2015. (Kirksey Smith, K)

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LINDA CLAXTON (SBN 125729)
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
400 South Hope Street, Suite 1200
Los Angeles, CA 90071
Telephone:
213.239.9800
Facsimile:
213.239.9045
Christopher M. Ahearn (SBN 239089)
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Steuart Tower, Suite 1300
One Market Plaza
San Francisco, CA 94105
Telephone:
415.442.4810
Facsimile:
415.442.4870

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Attorneys for Defendant
ADT LLC
Alan Harris (SBN 146079)
Priya Mohan (SBN 228984)
HARRIS & RUBLE
4771 Cromwell Avenue
Los Angeles, CA 90027
Telephone:
323.962.3777
Facsimile:
323.962.3004
[e-mail]
[e-mail]
David S. Harris (SBN 215224)
NORTH BAY LAW GROUP
116 E. Blithedale Avenue, Suite #2
Mill Valley, CA 94941-2024
Telephone:
415.388.8788
Facsimile:
415.388.8770

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Attorneys for Plaintiff Richard Castillo
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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RICARDO CASTILLO, individually and on
behalf of all others similarly situated,

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Plaintiff,
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v.

Case No. 2:15-cv-00383-WBS-DAD
JOINT STIPULATION AND [PROPOSED]
ORDER CONTINUING DATE FOR
DEFENDANT ADT LLC TO AMEND
ANSWER AS OF RIGHT

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ADT LLC and DOES 1–100, inclusive,
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Defendants.
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15cv383 Castillo Stip to Deft to
Amend
Answer.docx

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Case No. 2:15-cv-00383-WBS-DAD
JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DATE FOR DEFENDANT ADT LLC TO
AMEND ANSWER AS OF RIGHT

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Pursuant to Rules 137, 143 and 144 of the Local Rules of this Court, Plaintiff Ricardo

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Castillo (“Plaintiff”) and Defendant ADT LLC (“Defendant”) (collectively, the “Parties”)

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respectfully submit this Joint Stipulation and [Proposed] Order Continuing Defendant’s Date to

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Amend its Answer as of Right Pursuant to Fed. R. Civ. Proc. 15(a)(1)(A).

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WHEREAS, Defendant filed and served (via ECF) an Answer to Plaintiff’s Complaint on
March 20, 2015.
WHEREAS, Defendant’s time to amend its Answer as of right pursuant to Fed. R. Civ.
Proc. 15(a)(1)(A) is April 10, 2015.
WHEREAS, Plaintiff conferred with Defendant regarding Defendant’s affirmative defenses

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pleaded in the Answer, requesting that Defendant amend such defenses to state additional detail,

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and that Defendant consider withdrawing (without prejudice) defenses as to which such additional

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detail could not be stated at present.

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WHEREAS, Defendant has agreed to file an Amended Answer pursuant to this stipulation,
but requests an additional fourteen (14) days to do so.

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WHEREAS, Plaintiff stipulates to such an extension of time.

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WHEREAS, no extensions of time have been requested or given to either of the Parties

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with regard to the amendment of pleadings.
WHEREAS, the Parties stipulate to such an extension to avoid the potential need for
motion practice concerning Defendant’s affirmative defenses.
THEREFORE, the Parties stipulate that Defendant should have until April 24, 2015 to
amend its Answer as of right pursuant to Fed. R. Civ. Proc. 15(a)(1)(A).

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15cv383 Castillo Stip to Deft to
Amend
Answer.docx

DATED: April 7, 2015

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.
By: /s/ Christopher M. Ahearn
Linda Claxton
Christopher M. Ahearn
Attorneys for Defendant
ADT LLC

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Case No. 2:15-cv-00383-WBS-DAD
JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DATE FOR DEFENDANT ADT LLC TO
AMEND ANSWER AS OF RIGHT

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DATED: April 7, 2015

HARRIS & RUBLE

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By: /s/Alan Harris (as authorized on April 7, 2015)
Alan Harris
Priya Mohan

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Attorneys for Plaintiff
RICHARD CASTILLO

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DATED: April 7, 2015

NORTH BAY LAW GROUP

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By: /s/David S. Harris(as authorized on April 7, 2015)
David S. Harris

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Attorneys for Plaintiff
RICHARD CASTILLO

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ORDER

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Defendant’s time to amend its Answer to Plaintiff’s Complaint is continued from April 10,
2015 to April 24, 2015.

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IT IS SO ORDERED.

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Dated: April 7, 2015

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15cv383 Castillo Stip to Deft to
Amend
Answer.docx

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Case No. 2:15-cv-00383-WBS-DAD
JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DATE FOR DEFENDANT ADT LLC TO
AMEND ANSWER AS OF RIGHT