CE Resource, Inc. v. Jouria, et al.

Filing 10

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 11/4/15 ORDERING that Elite may have up to and including November 25, 2015, to file an answer or otherwise respond to the complaint. (Becknal, R)

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MOORE & VAN ALLEN, PLLC
Kathryn G. Cole (CA Bar No. 244307)
100 North Tryon Street, Suite 4700
Charlotte, North Carolina 28202-4003
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendant
Elite Continuing Education, Inc.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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CE RESOURCE, INC. d/b/a NetCE,
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Plaintiff,

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vs.
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DR. JASSIN JOURIA, an individual, and
ELITE CONTINUING EDUCATION, INC., a
Florida Corporation.

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Defendant.

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)
) Case No.: 2:15-cv-01908-WBS-DAD
)
)
) STIPULATED REQUEST FOR
) EXTENSION OF TIME
) TO RESPOND TO COMPLAINT
) (SECOND REQUEST)
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)

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SECOND STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT

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On October 7, 2015, the parties filed a stipulation pursuant to Eastern District Local Rule
144(a) stating that Defendant Elite Continuing Education, Inc. (“Elite”) may have up to and including
November 5, 2015 to file an answer or otherwise respond to the complaint. That was the first

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extension of time in this case and extended the time to file by twenty-eight days.
The parties now seek the Court’s approval to stipulate that Elite may have up to and including

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November 25, 2015, to file an answer or otherwise respond to the complaint. This is the second

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extension of time sought in this case.

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Elite seeks this extension in part because the other named Defendant in this matter, Dr. Jassin
Jouria, filed a Chapter 13 action in the United States Bankruptcy Court for the Southern District of

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Florida on October 23, 2015 (Case No. 15-28811-LMI). The complexities injected into the case by

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Dr. Jouria’s recent bankruptcy filing are still under review. Additionally, the undersigned counsel for

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Elite is traveling the remainder of this week for a court hearing in Arizona, and the requested extension

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of time is greatly appreciated.

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For these reasons, Defendant Elite requests that the Court grant the requested extension of time
to respond to Plaintiff’s complaint. Plaintiff has stipulated to this extension request.

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SECOND STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT

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Dated: November 4, 2015

Respectfully submitted,
/s/ Kathryn G. Cole
Kathryn G. Cole
CA Bar No. 244307
MOORE & VAN ALLEN, PLLC
100 North Tryon Street, Suite 4700
Charlotte, NC 28202-4003
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendant Elite Continuing
Education, Inc.

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/s/ John Kern
John Kern
CA Bar No. 206001
HOLLAND & KNIGHT LLP
50 California Street, 28th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Plaintiff CE Resource, Inc.
d/b/a/ NetCE

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In accordance with the foregoing stipulation IT IS SO ORDERED.
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Dated: November 4, 2015

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SECOND STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT