Lizama v. Medical Data Systems, Inc.
Filing
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STIPULATION and ORDER signed by Senior Judge William B. Shubb on 1/26/17: Defendant shall have an extension of time up to and including February 9, 2017 within which to respond to Plaintiff's Complaint. (Kaminski, H)
1 Todd M. Friedman (SBN 216752)
tfriedman@toddflaw.com
2 Meghan E. George (SBN 274525)
mgeorge@toddflaw.com
3 Adrian R. Bacon (SBN 280332)
abacon@toddflaw.com
4 LAW OFFICES OF TODD M. FRIEDMAN, P.C.
5 21550 Oxnard St.
Suite 780
6 Woodland Hills, CA 91367
Tel: 877-206-4741
7 Fax: 866-633-0228
Attorneys for Plaintiff
8 JONATHAN LIZAMA
9 David J. Kaminski (SBN 128509)
KaminskiD@cmtlaw.com
10 Shawn Eldridge (276581)
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EldridgeS@cmtlaw.com
CARLSON & MESSER LLP
5959 West Century Boulevard, Suite 1214
Los Angeles, CA 90045
Tel: (310) 242-2200
Fax: (310) 242-2222
Attorneys for Defendant
MEDICAL DATA SYSTEMS, INC., dba
MEDICAL DATA REVENUE SYSTEM
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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18 JONATHAN LIZAMA,
Plaintiff,
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vs.
21 MEDICAL DATA SYSTEMS, INC.,
dba MEDICAL DATA REVENUE
22 SYSTEM; DOES 1-100 AND EACH
OF THEM,
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Case No. 2:16-cv-02773-WBS-CKD
SECOND STIPULATION TO EXTEND
TIME TO RESPOND TO COMPLAINT
Complaint Served:
December 14, 2016
Current Response Due:
January 26, 2017
New Response Deadline: February 9, 2017
Defendants.
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IT IS HEREBY STIPULATED between Plaintiff JONATHAN LIZAMA
26 (“Plaintiffs”) and Defendants MEDICAL DATA SYSTEMS, INC. dba MEDICAL
27 DATA REVENUE SYSTEM (“Defendant”), through their respective counsel, as
28 follows:
{00060795;1} 08775.20
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SECOND STIPULATION TO EXTEND TIME
CASE NO. 2:16-cv-02773-WBS-CKD
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WHEREAS, Plaintiff served the Complaint on December 14, 2016;
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WHEREAS, a Stipulation to Extend Time to Answer was filed on December 29,
3 2016, extending the deadline for Defendant to respond to January 26, 2017 [Docket No.
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WHEREAS, Defendant, due to the press of business, needs additional time to
6 review documents to assist in an early resolution of the entire matter;
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WHEREAS, Plaintiff and Defendant (hereinafter referred to as “Parties”) have met
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and conferred and agree good cause exists to extend the deadline for Defendant to
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respond to Plaintiff’s Complaint to February 9, 2017;
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WHEREAS, no party claims prejudice as a result of the extension of time;
WHEREFORE, the Parties stipulate and agree that Defendant shall have an
extension of time up to and including February 9, 2017 within which to respond to
Plaintiff’s Complaint.
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LAW OFFICES OF TODD M. FRIEDMAN, P.C.
16 Dated: January 25, 2017
By: /s/ Adrian R. Bacon
Adrian R. Bacon
Attorney for Plaintiff
JONATHAN LIZAMA
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CARLSON & MESSER, LLP
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Dated: January 25, 2017
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By: /s/ Shawn Eldridge
Shawn Eldridge
Attorney for Defendant
MEDICAL DATA SYSTEMS, INC., dba
MEDICAL DATA REVENUE SYSTEM
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IT IS SO ORDERED.
Dated: January 26, 2017
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{00060795;1} 08775.20
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SECOND STIPULATION TO EXTEND TIME
CASE NO. 2:16-cv-02773-WBS-CKD
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ATTESTATION AND CERTIFCATE OF SERVICE
I, Shawn S. Eldridge, am the ECF user whose identification and password are
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being used to file the SECOND STIPULATION TO EXTEND TIME TO RESPOND TO
COMPLAINT, I hereby attest that all counsel whose electronic signatures in the
SECOND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT
provided their authority and concurrence to file that document.
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CARLSON & MESSER LLP
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Dated: January 25, 2017
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By: /s Shawn Eldridge
Shawn Eldridge
Attorney for Defendant,
MEDICAL DATA SYSTEMS, INC., dba
MEDICAL DATA REVENUE SYSTEM
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{00060795;1} 08775.20
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SECOND STIPULATION TO EXTEND TIME
CASE NO. 2:16-cv-02773-WBS-CKD
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CERTIFICATE OF SERVICE
I hereby certify that on January 25, 2017, a true and correct copy of the foregoing
SECOND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT was
served via the District Court ECF on the Following:
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6 Todd M. Friedman
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Meghan E. George
Adrian R. Bacon
LAW OFFICES OF TODD M. FRIEDMAN, P.C.
21550 Oxnard St.
Suite 780
Woodland Hills, CA 91367
Tel: 877-206-4741
Fax: 866-633-0228
Email: tfriedman@toddflaw.com
mgeorge@toddflaw.com
abacon@toddflaw.com
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CARLSON & MESSER, LLP
Dated: January 25, 2017
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By: /s/ Shawn Eldridge
David J. Kaminski
Shawn Eldridge
Attorneys for Defendant
MEDICAL DATA SYSTEMS, INC., dba
MEDICAL DATA REVENUE SYSTEM
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{00060795;1} 08775.20
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SECOND STIPULATION TO EXTEND TIME
CASE NO. 2:16-cv-02773-WBS-CKD
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