Horne v. Nissan North America, Inc.

Filing 10

STIPULATION and ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT signed by District Judge Morrison C. England, Jr on 4/18/17 ORDERING that the deadline for NNA to respond to Plaintiff's Complaint is 5/1/2017. (Mena-Sanchez, L)

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SHOOK, HARDY & BACON L.L.P.
Amir Nassihi (SBN 235936)
[e-mail]
One Montgomery, Suite 2700
San Francisco, California 94104-4505
Tel: [phone] | Fax: [phone]
Attorneys for Defendant
NISSAN NORTH AMERICA, INC.
FINKELSTEIN & KRINSK LLP
Jeffrey R. Krinsk (SBN 109234)
[e-mail]
Trenton R. Kashima (SBN 291405)
[e-mail]
550 West C. St., Suite 1760
San Diego, California 94101
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs
JANELLE HORNE

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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JANELLE HORNE, individually and on behalf
of all others similarly situated,
Plaintiffs,

Case No. 2:17-cv-00436-MCE-DB
STIPULATION AND ORDER TO EXTEND
TIME TO RESPOND TO COMPLAINT

v.
NISSAN NORTH AMERICA, INC., NISSAN
MOTOR CO., LTD.
Defendants.

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This Stipulation is entered into by and between Plaintiff Janelle Horne and Defendant Nissan

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North America, Inc. (“NNA”) (collectively, the “Parties”), by and through their respective counsel,

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with reference to the following facts and recitals:

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1.

On January 4, 2017, Plaintiff filed the Complaint in this action in the Superior Court

of the State of California in and for the County of Solano.

376938 V1

STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT
CASE NO. 2:17-CV-00436-MCE-DB

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2.

On February 27, 2017, NNA filed a Notice of Removal to this Court. (Dkt. 1)

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3.

Based on Plaintiff’s mailing of the complaint, NNA’s deadline to respond was

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originally April 3, 2017.

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4.

Parties previously submitted a stipulation to extend NNA’s time to respond by 21

days. As a result, NNA’s response to the Complaint is currently due on April 24, 2017. (Dkt. 6)

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5.

Pursuant to Local Rule 144, NNA requested and Plaintiff consented to an additional

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7-day extension of time for NNA to respond to the Complaint. The total extension, to respond to the

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complaint, which includes the prior stipulated extension, is a total of 28 days.

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6.

Good cause exists for this request as Counsel for NNA has had a number of other

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obligations, including appellate and trial court briefing, an appellate argument, and lengthy travel

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obligations.

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IT IS HEREBY STIPULATED by and between the parties, through their respective

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counsel, that NNA shall have an additional 7 days to respond to Plaintiff’s complaint, up to and

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including May 1, 2017 in which to answer, move, or respond to the Complaint.

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Dated: April 14, 2017

SHOOK, HARDY & BACON L.L.P.
By:

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/s/ Amir Nassihi___________
Amir Nassihi

Attorneys for Defendant
NISSAN NORTH AMERICA, INC.

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Dated: April 14, 2017

FINKELSTEIN & KRINSK LLP
By: /s/ Trenton Kashima (as authorized on 4/14/17)
Trenton Kashima

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Attorneys for Plaintiff
JANELLE HORNE

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///

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STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT
376938 v1

CASE NO. 2:17-cv-00436-MCE-DB

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ORDER
Pursuant to the parties’ Stipulation, the deadline for NNA to respond to Plaintiff’s Complaint
is May 1, 2017.
IT IS SO ORDERED.
Dated: April 18, 2017

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STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT
376938 v1

CASE NO. 2:17-cv-00436-MCE-DB