Universal Security and Fire, Inc. v. Alpha Alarm & Audio, Inc. et al

Filing 14

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 6/27/17 ORDERING that Defendant, FRANK CHARLES YANEZ is ordered to file his response to Plaintiff, UNIVERSAL SECURITY AND FIRE, INC.'s Complaint, including, but not limited to, any motions to dismiss, motions to compel arbitration, or motions related to personal jurisdiction, no later than 7/5/17. (Becknal, R)

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1 2 3 4 5 6 Jennifer E. Duggan, SBN: 183833 Christina M. Bucci, SBN: 292047 DUGGAN LAW CORPORATION 641 Fulton Ave., Suite 200 Sacramento, CA 95825 Telephone: 916.550.5309 Facsimile: 916.404.5900 jennifer@duggan-law.com Attorneys for Defendant FRANK CHARLES YANEZ 7 UNITED STATES DISTRICT COURT 8 EASTERN DISTRICT OF CALIFORNIA 9 10 UNIVERSAL SECURITY AND FIRE, INC., a California Corporation, 11 14 15 vs. ALPHA ALARM & AUDIO, INC., a California Corporation; FRANK CHARLES YANEZ; and DOES 1 through 30, Inclusive, 17 19 Pursuant to Civil Local Rule 1, Plaintiff, UNIVERSAL SECURITY AND FIRE, INC. and Defendant, FRANK CHARLES YANEZ, by and through their respective attorneys of record, Omar M. Farooqui, Jennifer E. Duggan, and Christina M. Bucci, stipulate as follows: 20 21 22 1. 25 Defendant, FRANK CHARLES YANEZ is granted an extension of time until July 5, 2017 to respond or otherwise plead in reference to Plaintiff, UNIVERSAL SECURITY AND FIRE INC.’s Complaint; 23 24 Hon. Troy L. Nunley Defendants. 16 18 STIPULATION AND ORDER RE: EXTENSION OF TIME UNTIL JULY 5, 2017 FOR DEFENDANT, FRANK CHARLES YANEZ TO RESPOND TO PLAINTIFF’S COMPLAINT Plaintiff, 12 13 Case No. 2:17-cv-00844-TLN-CKD 2. Defendant, FRANK CHARLES YANEZ’s response, including, but not limited to any motions to dismiss, motions to compel arbitration, or motions related to personal jurisdiction, will be due no later than July 5, 2017. 26 /// 27 /// 28 DUGGAN LAW CORPORATION 641 FULTON AVE., SUITE 200A SACRAMENTO, CA 95825 916.550-5309 STIPULATION AND ORDER RE: EXTENSION OF TIME UNTIL JULY 5, 2017 FOR DEFENDANT, FRANK CHARLES YANEZ TO RESPOND TO PLAINTIFF’S COMPLAINT 1. 3. 1 The reason for the requested enlargement of time is for the purpose of the parties to 2 meet and confer as to the deficiencies in the operative Complaint without incurring the costs and fees 3 associated with any motions to dismiss, motion to compel arbitration, or motions related to personal 4 jurisdiction; 5 4. No prior modifications have been made in the case by stipulation or by Court order; 6 5. The requested time modification should have no effect on the overall schedule for the 7 8 case. IT IS SO STIPULATED effective as of June 27, 2017. 9 Dated: June 27, 2017 ELLAHIE & FAROOQUI, LLP 10 11 By: /s/ Omar M. Farooqui ______ Omar M. Farooqui Attorneys for Plaintiff, UNIVERSAL SECURITY AND FIRE, INC. 12 13 14 15 Dated: June 27, 2017 DUGGAN LAW CORPORATION 16 By: /s/ Christina M. Bucci ______ Jennifer E. Duggan Christina M. Bucci Attorneys for Defendant, FRANK CHARLES YANEZ 17 18 19 20 21 22 23 24 25 26 27 28 DUGGAN LAW CORPORATION 641 FULTON AVE., SUITE 200A SACRAMENTO, CA 95825 916.550-5309 STIPULATION AND ORDER RE: EXTENSION OF TIME UNTIL JULY 5, 2017 FOR DEFENDANT, FRANK CHARLES YANEZ TO RESPOND TO PLAINTIFF’S COMPLAINT 2. 1 ATTESTATION OF CONCURRENCE 2 I, Christina M. Bucci, attest that I am one of the attorneys for Defendant, FRANK 3 CHARLES YANEZ. As the ECF user and filer of this document, I attest that concurrence in the 4 filing of this document has been obtained from its signatories. 5 Dated: June 27, 2017 DUGGAN LAW CORPORATION 6 7 By: /s/ Christina M. Bucci___________ Jennifer E. Duggan Christina M. Bucci Attorneys for Defendant, FRANK CHARLES YANEZ 8 9 10 11 CERTIFICATE OF SERVICE 12 13 The undersigned counsel for Defendant, FRANK CHARLES YANEZ, hereby certifies that a 14 true and correct copy of the foregoing document was filed with the Court and served electronically 15 through the CM-ECF (electronic case filing) system to all counsel of record to those registered to 16 receive a Notice of Electronic Filing for this case on June 27, 2017. 17 Dated: June 27, 2017 DUGGAN LAW CORPORATION 18 By: /s/ Christina M. Bucci___________ Jennifer E. Duggan Christina M. Bucci Attorneys for Defendant, FRANK CHARLES YANEZ 19 20 21 22 23 24 25 26 27 28 DUGGAN LAW CORPORATION 641 FULTON AVE., SUITE 200A SACRAMENTO, CA 95825 916.550-5309 STIPULATION AND ORDER RE: EXTENSION OF TIME UNTIL JULY 5, 2017 FOR DEFENDANT, FRANK CHARLES YANEZ TO RESPOND TO PLAINTIFF’S COMPLAINT 3. 1 ORDER 2 Upon consideration of the foregoing Stipulation, and good cause appearing therefore, 3 IT IS HEREBY ORDERED: 4 5 1. Defendant, FRANK CHARLES YANEZ is ordered to file his response to Plaintiff, 6 UNIVERSAL SECURITY AND FIRE, INC.’s Complaint, including, but not limited to, any motions 7 to dismiss, motions to compel arbitration, or motions related to personal jurisdiction, no later than 8 July 5, 2017 9 Dated: June 27, 2017 10 11 Troy L. Nunley United States District Judge 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DUGGAN LAW CORPORATION 641 FULTON AVE., SUITE 200A SACRAMENTO, CA 95825 916.550-5309 STIPULATION AND ORDER RE: EXTENSION OF TIME UNTIL JULY 5, 2017 FOR DEFENDANT, FRANK CHARLES YANEZ TO RESPOND TO PLAINTIFF’S COMPLAINT 4.

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