Hayes v. NextGen Leads, LLC

Filing 8

STIPULATION AND ORDER signed by District Judge Morrison C. England, Jr. on 4/12/2017 ORDERING the defendant to answer or otherwise respond to the 1 Complaint by 5/2/2017. (Michel, G.)

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VENABLE LLP
Ari N. Rothman (SBN 296568)
Email: [e-mail]
Bety Javidzad (SBN 240598)
Email: [e-mail]
2049 Century Park East, Suite 2300
Los Angeles, CA 90067
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
NEXTGEN LEADS, LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORIA

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SUSAN HAYES, individually and on
behalf of all others similarly situated,
Plaintiff,

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310-229-9900

LOS ANGELES, CA 90067

VENABLE LLP

2049 CENTURY PARK EAST, SUITE 2300

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v.

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NEXTGEN LEADS, LLC, and DOES 1
through 10, inclusive, and each of them,

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Defendant.

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CASE NO. 2:17-cv-00324-MCE-GGH
Hon. Morrison C. England, Jr.
Courtroom 7
STIPULATION AND ORDER TO
EXTEND DEFENDANT
NEXTGEN LEADS, LLC’S TIME
TO RESPOND TO PLAINTIFF’S
COMPLAINT
[L.R. 144]
Action Filed: February 14, 2017
Trial Date:
None Set

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STIPULATION TO EXTEND DEFENDANT’S TIME TO RESPOND TO COMPLAINT
14945812-v1

Plaintiff Susan Hayes and defendant NextGen Leads, LLC, by and through

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their respective counsel of record, hereby stipulate as follows:
WHEREAS, on February 14, 2017, plaintiff filed the complaint in the

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United States District Court for the Eastern District of California (ECF No. 1);
WHEREAS, on February 21, 2017, plaintiff served the complaint on

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defendant;
WHEREAS, defendant currently has until April 11, 2017 to answer or

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otherwise respond to plaintiff’s complaint;

twenty-one (21) days for defendant to answer or otherwise respond to plaintiff’s

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complaint;
WHEREAS, pursuant to Federal Rule of Civil Procedure Rule 6 and Eastern

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310-229-9900

LOS ANGELES, CA 90067

VENABLE LLP

WHEREAS, defendant requested, and plaintiff consented, to an additional

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2049 CENTURY PARK EAST, SUITE 2300

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District of California Local Rule 144, the parties agree to extend the defendant’s

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time to respond to the complaint through and including May 2, 2017;
WHEREAS, good cause exists to grant an extension of time for defendant to

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respond to the complaint until May 2, 2017 because defendant voluntarily

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produced information to expedite prompt resolution of this matter and the parties

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are currently engaging in settlement discussions;
WHEREAS, an additional twenty-eight (21) days for defendant to respond

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to plaintiff’s complaint will not alter the date of any event or any deadline already

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fixed by Court order, or prejudice any party;
THEREFORE, IT IS HEREBY STIPULATED by and between the parties,

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through their respective counsel, that defendant’s time to answer or otherwise

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respond to plaintiff’s complaint shall be extended through and including May 2,

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2017.

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Dated:

April 12, 2017

VENABLE LLP

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By: /s/ Ari N. Rothman
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14945812-v1STIPULATION

TO EXTEND DEFENDANT’S TIME TO RESPOND TO COMPLAINT; ORDER

Ari N. Rothman
Bety Javidzad
Attorneys for Defendant NEXTGEN
LEADS, LLC

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Dated:

April 12, 2017

LAW OFFICES OF TODD M.
FRIEDMAN

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By: /s/ Todd M. Friedman
Todd M. Friedman
Attorneys for Plaintiff SUSAN
HAYES

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I, Ari N. Rothman, attest that all signatories listed, and on whose behalf the
filing is submitted, concur in the filing’s content and have authorized the filing.

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310-229-9900

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LOS ANGELES, CA 90067

VENABLE LLP

2049 CENTURY PARK EAST, SUITE 2300

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ATTESTATION REGARDING SIGNATURES

Dated: April 12, 2017

VENABLE LLP

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By: /s/ Ari N. Rothman
Ari N. Rothman
Bety Javidzad
Attorneys for Defendant NEXTGEN
LEADS, LLC

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ORDER

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Pursuant to the stipulation of the parties and good cause appearing, it is
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hereby ordered that Defendant’s time to answer or otherwise respond to Plaintiff’s
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complaint shall be extended through and including May 2, 2017.
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IT IS SO ORDERED.
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DATED: April 12, 2017
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_______________________________________
MORRISON C. ENGLAND, JR.
UNITED STATES DISTRICT JUDGE

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14945812-v1STIPULATION

TO EXTEND DEFENDANT’S TIME TO RESPOND TO COMPLAINT; ORDER