Kellum v. The University of Phoenix, Inc.

Filing 11

STIPULATION and ORDER signed by District Judge John A. Mendez on 2/13/17 ORDERING that the Parties' Request for a thirty (30) day extension of the filing deadline for Defendant's response to Plaintiff's Complaint and the filing deadline for the Joint Status Report, IS HEREBY GRANTED. Defendants response to the Complaint shall be due on 3/17/17. The Joint Status Report shall be due on 4/1/17. (Mena-Sanchez, L)

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LITTLER MENDELSON, P.C.
BENJAMIN L. WEBSTER, Bar No. 132230
[e-mail]
JOHNNY A. COLÓN, Bar No. 294447
[e-mail]
500 Capitol Mall, Suite 2000
Sacramento, CA 95814
Telephone:
916.830.7200
Facsimile:
916.561.0828
Attorneys for Defendant
THE UNIVERSITY OF PHOENIX, INC.

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VAUGHAN & ASSOCIATES
CRIS C. VAUGHAN, Bar No. 99568
[e-mail]
6207 South Walnut Street, Suite 800
Loomis, CA 95650
Telephone:
916.660.9401
Facsimile:
916660.9378

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Attorney for Plaintiff
JACK C. KELLUM

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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JACK C. KELLUM,

Case No. 2:16-cv-02678-JAM-KJN

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Plaintiff,
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v.
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THE UNIVERSITY OF PHOENIX, INC.;
and DOES 1-50, inclusive,
Defendant.

STIPULATION AND ORDER GRANTING
EXTENSION OF TIME FOR DEFENDANT
TO RESPOND TO PLAINTIFF’S
COMPLAINT AND TO SUBMIT JOINT
STATUS REPORT (LOCAL RULE 144(a))
Current Response Date:
New Response Date:

February 15, 2017
March 17, 2017

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Firmwide:145783452.1 073540.1121
LITTLER MENDELSON, P.C.
500 Capitol Mall
Suite 2000
Sacramento, CA 95814
916.830.7200

Case No. 2:16-cv-02678-JAM-KJN

STIPULATION AND [PROPOSED] ORDER GRANTING EXTENSION OF TIME TO RESPOND TO
COMPLAINT

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Pursuant to Eastern District Local Rule 144(a), Plaintiff Jack C. Kellum (“Plaintiff”)

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and Defendant the University of Phoenix, Inc. (“UOP”) (collectively the “Parties”) hereby stipulate

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and request a thirty (30) day extension of time for UOP to answer or otherwise respond to Plaintiff’s

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Complaint. The Parties also request the same extension of time for the parties to submit their Joint

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Status Report. This is the Parties’ second request for an extension of time from this Court.

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Good cause exists as the Parties are continuing to engage in good faith discussions

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regarding the terms and conditions of a proposed settlement agreement. Since the last extension of

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time, the Parties have made significant progress regarding the proposed settlement agreement (e.g.,

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they have reached an agreement in principle for Plaintiff to re-take a set number of classes at UOP

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free of charge). The Parties, however, need an additional extension to resolve additional terms and

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conditions regarding Plaintiff’s return to UOP, e.g., grade point average needed to confer his Master

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in Business Administration and additional accommodations. The Parties respectfully request this

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Court to grant an additional extension to allow the Parties to continue and conclude their productive

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settlement discussions.

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IT IS SO STIPULATED.
Dated: February 13, 2017

VAUGHAN & ASSOCIATES

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/s/ _Cris A. Vaughan
CRIS A. VAUGHAN
ATTORNEYS FOR PLAINTIFF
JACK C. KELLUM

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Dated: February 13, 2017

LITTLER MENDELSON, P.C.

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/s/ Johnny A. Colón
BENJAMIN L. WEBSTER
JOHNNY A. COLÓN
ATTORNEYS FOR DEFENDANT
THE UNIVERSITY OF PHOENIX, INC.

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Firmwide:145783452.1 073540.1121
LITTLER MENDELSON, P.C.
500 Capitol Mall
Suite 2000
Sacramento, CA 95814
916.830.7200

Case No. 2:16-cv-02678-JAM-KJN

STIPULATION AND [PROPOSED] ORDER GRANTING EXTENSION OF TIME TO RESPOND TO
COMPLAINT

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ORDER

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For good cause, the Parties’ request for a thirty (30) day extension of the filing

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deadline for Defendant’s response to Plaintiff’s Complaint and the filing deadline for the Joint Status

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Report, IS HEREBY GRANTED. Defendant’s response to the Complaint shall be due on March 17,

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2017. The Joint Status Report shall be due on April 1, 2017.

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IT IS SO ORDERED.

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Dated: 2/13/2017

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/s/ John A. Mendez__________
JUDGE JOHN A. MENDEZ

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Firmwide:145783452.1 073540.1121
LITTLER MENDELSON, P.C.
500 Capitol Mall
Suite 2000
Sacramento, CA 95814
916.830.7200

Case No. 2:16-cv-02678-JAM-KJN

STIPULATION AND [PROPOSED] ORDER GRANTING EXTENSION OF TIME TO RESPOND TO
COMPLAINT