Lingle et al v. Alliance Health Networks, LLC

Filing 8

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 4/4/17 ORDERING that Defendant's time to respond to the Complaint is EXTENDED to 5/8/2017. The time for the parties to file their joint report is EXTENDED up to and including 5/16/17, or such other date as the Court may find appropriate. (Mena-Sanchez, L)

1
2
3
4
5
6

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

7

UNITED STATES DISTRICT COURT

8

EASTERN DISTRICT OF CALIFORNIA

9
10
11
12

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

13

Plaintiffs,

14
15
16

v.

Case No. 2:17-cv-00056-TLB-DB
CLASS ACTION
STIPULATION AND ORDER
EXTENDING TIME TO ANSWER
COMPLAINT AND EXTENDING
TIME TO FILE JOINT REPORT

ALLIANCE HEALTH NETWORKS,
LLC,

17
Defendant.

18
19
20
21
22
23
24
25
26
27

WHEREAS, it is hereby stipulated by and between the parties, through their
respective attorneys of record, as follows:
WHEREAS, Plaintiffs filed their Complaint in this action on January 10,
2017 in the United States District Court for the Eastern District of California;
WHEREAS, the deadline for Defendant to respond to the Complaint is April
7, 2017;
WHEREAS, the parties are engaged in discussions expected to lead to an
early resolution of this matter;
WHEREAS, Defendant seeks an extension of time of thirty (30) days to

28
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

1
2
3
4
5

serve and file its response to the Complaint;
WHEREAS, pursuant to this Court’s January 10, 2017 Order (Dkt. 3), the
current deadline for the parties to submit a joint status report is April 4, 2017;
WHEREAS, the parties jointly request a forty-five (45) day extension to
submit their joint report;

6

WHEREAS, the requested extension will promote efficiency and settlement

7

by enabling the parties to continue pursuing a preliminary settlement and possibly

8

secure a speedy resolution of this matter without incurring legal expenses in

9

preparing a responsive pleading and joint report, that would necessitate further

10
11
12

litigation expense and judicial labor.
WHEREAS, the parties not seek the requested extension for purposes of
delay, but rather to enable their attorneys pursue an early resolution of this dispute.

13

THEREFORE, the parties stipulate to and respectfully request an order

14

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

15

May 8, 2017, and extending the time for the parties to file their joint report, up to

16

and including May 16, 2017, or such other date as the Court may find appropriate.

17

Respectfully submitted,

18
19

Dated: April 4, 2017

20

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

21
22
23

MANATT, PHELPS & PHILLIPS, LLP

Dated: April 4, 2017

LAW OFFICES OF TODD FRIEDMAN

24
25
26
27

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

28
M ANATT , P HELPS &
P HILLIPS , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

-2-

CASE NO. 17CV00056

STIPULATION AND ORDER EXTENDING TIME TO ANSWER

1
2

IT IS SO ORDERED.

3
4

Dated: April 04, 2017

5
6

Troy L. Nunley
United States District Judge

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
M ANATT , P HELPS &
P HILLIPS , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

-3-

CASE NO. 17CV00056

STIPULATION AND ORDER EXTENDING TIME TO ANSWER