Lizama v. Medical Data Systems, Inc.

Filing 8

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)

[e-mail]

2 Meghan E. George (SBN 274525)

[e-mail]

3 Adrian R. Bacon (SBN 280332)

[e-mail]

4 LAW OFFICES OF TODD M. FRIEDMAN, P.C.
5 21550 Oxnard St.

Suite 780
6 Woodland Hills, CA 91367
Tel: [phone]
7 Fax: [phone]
Attorneys for Plaintiff
8 JONATHAN LIZAMA

9 David J. Kaminski (SBN 128509)

[e-mail]

10 Shawn Eldridge (276581)
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[e-mail]
CARLSON & MESSER LLP
5959 West Century Boulevard, Suite 1214
Los Angeles, CA 90045
Tel: [phone]
Fax: [phone]
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: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
[e-mail]

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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