Havens v. AutoZoners, LLC et al

Filing 22

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 07/14/17 ORDERING that the deadline for Defendants to file a responsive pleading to the Second Amended Complaint is EXTENDED to 07/14/17. (Benson, A)

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MICHAEL HOFFMAN, Bar No. 162496
CONOR D. MACK, Bar No. 253878
ARENA HOFFMAN LLP
44 Montgomery Street, Suite 3520
San Francisco, CA 94104-4828
Telephone:
415.433.1414
Facsimile:
415.520.0446
Email:
[e-mail]

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Attorneys for Defendants
AUTOZONERS, LLC and ALLDATA, LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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LADY CHRISTIAN HAVENS,

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Case No. 2:16-cv-02503-KJM-GGH

Plaintiff,
v.
AUTOZONERS, LLC; ALLDATA, LLC;
and DOES 1 through 50, inclusive,
Defendants.

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STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME TO RESPOND
TO COMPLAINT BY NOT MORE THAN
30 DAYS; AND [PROPOSED] ORDER
THEREON (L.R. 8-3)
2nd Am. Compl. served: June 27, 2017
Responsive pleading due: July 11, 2017
New response deadline: July 14, 2017

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IT IS HEREBY STIPULATED, by and between all parties to the action, to the following:
Defendants’ responsive pleading to the operative Second Amended Complaint is currently
due on July 11, 2017.

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Pursuant to the Court’s Standing Order, defense counsel and Plaintiff’s counsel met and

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conferred regarding Defendants’ anticipated motion to dismiss the fifth cause of action for

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defamation in the Second Amended Complaint.

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Plaintiff’s counsel and defense counsel conferred by phone regarding a potential motion on July 10.

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Plaintiff and Defendants seek a few more days to deliberate on the remaining issues to be presented

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in the motion and possibly resolve the dispute.

In addition to exchanging correspondence,

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ARENA HOFFMAN LLP

44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4828
415.433.1414

STIPULATION RE RESP. TO COMPLAINT

Case No. 2:16-cv-02503-KJM-GGH

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Accordingly, pursuant to Local Rule 144(a), Plaintiff and Defendants stipulate to extend the
time for Defendants to respond to the Second Amended Complaint until July 14, 2017. Good cause
exists to extend the time for Defendants to respond to the Second Amended Complaint so that the
parties may try to avoid a motion to dismiss, or narrow the issues raised in a motion to dismiss.

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Dated: July 11, 2017
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/s/ Erik M. Roper
Erik M. Roper
Law Office of Erik M. Roper
Counsel for Plaintiff
LADY CHRISTIAN HAVENS

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Dated: July 11, 2017
/s/ Michael Hoffman
Michael Hoffman
Arena Hoffman LLP
Counsel for Defendants
AUTOZONERS, LLC and ALLDATA, LLC

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ORDER

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Pursuant to stipulation and good cause appearing, the deadline for Defendants to file a
responsive pleading to the Second Amended Complaint shall be extended to July 14, 2017.
IT IS SO ORDERED.
DATED: July 14, 2017.

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UNITED STATES DISTRICT JUDGE

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ARENA HOFFMAN LLP
44 Montgomery Street
Suite 3520
San Francisco, CA 94104
415.433.1414

STIPULATION RE RESP. TO COMPLAINT

2.

Case No. 2:16-cv-02503-KJM-GGH