Bruno v. Equifax Credit Information Services, LLC, et al.

Filing 19

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 3/31/2017 ORDERING; the deadling for American Marketing and Mailing Services, Inc. to answer move, or otherwise respond to the complaint is EXTENDED until 4/12/2017. (Washington, S)

1
2
3
4
5
6
7
8

One Embarcadero Center, Suite 2860
San Francisco, CA 94111
Tel. [phone] Fax. [phone]

DE LA PEÑA & HOLIDAY LLP

9

GREGORY R. DE LA PEÑA, California State Bar No. 126626
Email: [e-mail]
MALCOLM E. McLORG, California State Bar No. 40956
Email: [e-mail]
ROBERT CARROLL, III, California State Bar No. 314345
Email: [e-mail]
DE LA PEÑA & HOLIDAY, LLP
One Embarcadero Center, Suite 2860
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
AMERICAN MARKETING AND
MAILING SERVICESS, INC.

10

UNITED STATES DISTRICT COURT

11

EASTERN DISTRICT OF CALIFORNIA

12
13

DANIEL BRUNO, individually and on behalf of
other similarly situated,

14
15
16
17
18
19
20

CASE NO.: 2:17-cv-327-WBS-EFB

Plaintiffs,

STIPULATED MOTION FOR
ENLARGEMENT OF TIME TO
RESPOND TO COMPLAINT AND
MEMORANDUM OF LAW;
[PROPOSED] ORDER

v.
EQUIFAX INFORMATION SERVICES, LLC;
GENEVA FINANCIAL SERVICES, LLC;
EMB WORK ENTERPRISES, LLC, dba
DECISION LINKS; B.B. DIRECT, INC.;
GENESIS MARKETING GROUP, INC., dba
HITMAN DIRECT; AMERICAN
MARKETING AND MAILING SERVICES,
INC.; and S TRATEGIC MARKETING
SERVICES, LLC,

21

Defendants.

22
23
24

Pursuant to Rule 6(b)(1)(A), Federal Rules of Civil Procedure and Local Rule 6-144,
Plaintiff, Daniel Bruno (“Plaintiff”), and Defendant, American Marketing and Mailing Services,

25
26
27
28

Inc. (“AMMS”), move the Court on the following grounds for an enlargement of time of twentyone (21) days, through April 12, 2017, for AMMS to file a response to the Complaint (Doc. No. 1):
1.

AMMS was served with the Complaint on March 1, 2017.

STIP AND [PROPOSED] ORDER
EXTENDING TIME

1

Case No. 2:17-cv-327-WBS-EFB

1

2.

AMMS’s response to the Complaint is due to be served on March 22, 2017.

2

3.

AMMS has requested a twenty-one (21) day extension in which to respond to the

3

Complaint.

4
4.

Plaintiff does not oppose the requested extension of time.

5
6
7

MEMORANDUM OF LAW
Under Rule 6(b)(1)(A), Federal Rules of Civil Procedure, this Court has the authority to

One Embarcadero Center, Suite 2860
San Francisco, CA 94111
Tel. [phone] Fax. [phone]

extend the time for responding to the Complaint as this request is made before the time has expired.

9

DE LA PEÑA & HOLIDAY LLP

8

AMMS seeks a twenty-one (21) day extension of time in which to file its response to the

10

Complaint. Plaintiff has stipulated to the extension and is not prejudiced by this request as there are

11

no pending deadlines in this case. Thus good cause exists to grant this extension.

12
13

WHEREFORE, Plaintiff and AMMS respectfully request the Court enter an Order granting

14

their request for an enlargement of time through April 12, 2017, for AMMS to file its response to

15

the Complaint, and to grant all such other relief as this Court deems just and proper.

16

Dated: March 23, 2017

By /s/ Gregory R. de la Peña
Gregory R. de la Peña (SBN 126266)
DE LA PEÑA & HOLIDAY LLP
One Embarcadero Center, Suite 2860
San Francisco, CA 94111
Tel: [phone]
Fax: [phone]
Attorneys for Defendant AMERICAN
MARKETING AND MAILING SERVICES, LLC

Dated: March 23, 2017

By /s/ James Louis Kohl
James Louis Kohl (SBN 120808)
795 Folsom Street, First Floor
San Francisco, CA 94107
Tel: [phone]
Fax: [phone]
Attorney for Plaintiff DANIEL BRUNO

17
18
19
20
21
22
23
24
25
26
27
28
STIP AND [PROPOSED] ORDER
EXTENDING TIME

2

Case No. 2:17-cv-327-WBS-EFB

1

ORDER

2

Pursuant to the parties’ stipulation, IT IS SO ORDERED that the deadline for Defendant

3

AMERICAN MARKETING AND MAILING SERVICES, LLC, to answer move, or otherwise

4

respond to the complaint is extended until April 12, 2017.

5
6
7

Dated: March 31, 2017

8

One Embarcadero Center, Suite 2860
San Francisco, CA 94111
Tel. [phone] Fax. [phone]

DE LA PEÑA & HOLIDAY LLP

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIP AND [PROPOSED] ORDER
EXTENDING TIME

3

Case No. 2:17-cv-327-WBS-EFB