Lingle et al v. Alliance Health Networks, LLC

Filing 6

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 2/23/17: The time for Defendant to respond to the Complaint is extended until and including April 7, 2017.(Kaminski, H)

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MANATT, PHELPS & PHILLIPS, LLP
Christine M. Reilly (SBN 226388)
[e-mail]
11355 W. Olympic Boulevard
Los Angeles, CA 90064
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
ALLIANCE HEALTH NETWORKS, LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JEFF LINGLE AND XUANDAO
GRAY-LINGLE, INDIVIDUALLY
AND ON BEHALF OF ALL OTHERS
SIMILARLY SITUATED,

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Plaintiffs,

Case No. 2:17-cv-00056-TLB-DB
CLASS ACTION
STIPULATION EXTENDING TIME
TO ANSWER COMPLAINT

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v.
ALLIANCE HEALTH NETWORKS,
LLC,

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Defendant.
WHEREAS, it is hereby stipulated by and between the parties, through the
respective attorneys of record, as follows:

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WHEREAS, Plaintiff filed his Complaint in this action on January 10, 2017

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in the United States District Court for the Eastern District of California and served

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the Complaint on February 3, 2017.

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WHEREAS, pursuant to Rule 21 of the Federal Rules of Civil Procedure, the
current deadline for Defendant to respond to the Complaint is February 24, 2017.

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WHEREAS, Defendant recently retained counsel in this matter.

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WHEREAS, Defendant seeks an extension of time of forty-five (45) days to

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CASE NO. 17CV00056

M ANATT , P HELPS &
P HILLIPS , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

STIPULATION EXTENDING TIME TO ANSWER

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serve and file its response to the Complaint.

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WHEREAS, Having just recently been retained, the requested extension is

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necessary for Defendant’s counsel to complete a thorough review and analysis of

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the Complaint’s allegations, research the underlying facts, and formulate a

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sufficient response by answer or motion.

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WHEREAS, The requested extension will also promote efficiency and

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settlement by enabling Defendant to further pursue a preliminary settlement

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dialogue and possibly secure a speedy resolution of this matter without incurring

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legal expenses in preparing a responsive pleading, including a Rule 12(b) motion

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that would necessitate further litigation expense and judicial labor.

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WHEREAS, Defendant does not seek the requested extension for purposes of

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delay, but rather to enable its attorneys to formulate a sufficient responsive pleading

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after pursuing an early resolution of this dispute.

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THEREFORE, the parties stipulate to and respectfully request an order

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extending the time for Defendant to respond to the Complaint until and including

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April 7, 2017, or such other date as the Court may find appropriate.

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Respectfully submitted,

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Dated: February 23, 2017

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By: /s/ Christine M. Reilly
Attorneys for Defendant
ALLIANCE HEALTH NETWORKS,
LLC

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MANATT, PHELPS & PHILLIPS, LLP

Dated: February 23, 2017

LAW OFFICES OF TODD FRIEDMAN

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/s Adrian R. Bacon
Adrian R. Bacon, Esq.
Attorney for Plaintiffs
Jeff Lingle and Xuandao Gray-Lingle

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T ROU TMA N S ANDE RS LLP
11682 EL CAMINO REAL
SUITE 400
SAN DIEGO, CA 92130-2092

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POINTS & AUTHORITIES IN SUPPORT OF
MOTION TO DISMISS COMPLAINT

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IT IS SO ORDERED.

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Dated: February 23, 2017
Troy L. Nunley
United States District Judge

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T ROU TMA N S ANDE RS LLP
11682 EL CAMINO REAL
SUITE 400
SAN DIEGO, CA 92130-2092

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POINTS & AUTHORITIES IN SUPPORT OF
MOTION TO DISMISS COMPLAINT