(PS) Universal Security and Fire, Inc. v. Yanez

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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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
[e-mail]
Attorneys for Defendant
FRANK CHARLES YANEZ

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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UNIVERSAL SECURITY AND FIRE,
INC., a California Corporation,

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vs.
ALPHA ALARM & AUDIO, INC., a
California Corporation; FRANK
CHARLES YANEZ; and DOES 1
through 30, Inclusive,

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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:

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1.

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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;

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Hon. Troy L. Nunley

Defendants.

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STIPULATION AND ORDER RE:
EXTENSION OF TIME UNTIL
JULY 5, 2017 FOR DEFENDANT,
FRANK CHARLES YANEZ TO
RESPOND
TO
PLAINTIFF’S
COMPLAINT

Plaintiff,

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Case No. 2:17-cv-00844-TLN-CKD

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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.

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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

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3.

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The reason for the requested enlargement of time is for the purpose of the parties to

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meet and confer as to the deficiencies in the operative Complaint without incurring the costs and fees

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associated with any motions to dismiss, motion to compel arbitration, or motions related to personal

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jurisdiction;

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4.

No prior modifications have been made in the case by stipulation or by Court order;

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5.

The requested time modification should have no effect on the overall schedule for the

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case.
IT IS SO STIPULATED effective as of June 27, 2017.

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Dated: June 27, 2017

ELLAHIE & FAROOQUI, LLP

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By: /s/ Omar M. Farooqui ______
Omar M. Farooqui
Attorneys for Plaintiff,
UNIVERSAL SECURITY AND FIRE, INC.

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Dated: June 27, 2017

DUGGAN LAW CORPORATION

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By: /s/ Christina M. Bucci
______
Jennifer E. Duggan
Christina M. Bucci
Attorneys for Defendant,
FRANK CHARLES YANEZ

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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

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ATTESTATION OF CONCURRENCE

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I, Christina M. Bucci, attest that I am one of the attorneys for Defendant, FRANK

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CHARLES YANEZ. As the ECF user and filer of this document, I attest that concurrence in the

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filing of this document has been obtained from its signatories.

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Dated: June 27, 2017

DUGGAN LAW CORPORATION

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By: /s/ Christina M. Bucci___________
Jennifer E. Duggan
Christina M. Bucci
Attorneys for Defendant,
FRANK CHARLES YANEZ

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CERTIFICATE OF SERVICE

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The undersigned counsel for Defendant, FRANK CHARLES YANEZ, hereby certifies that a

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true and correct copy of the foregoing document was filed with the Court and served electronically

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through the CM-ECF (electronic case filing) system to all counsel of record to those registered to

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receive a Notice of Electronic Filing for this case on June 27, 2017.

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Dated: June 27, 2017

DUGGAN LAW CORPORATION

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By: /s/ Christina M. Bucci___________
Jennifer E. Duggan
Christina M. Bucci
Attorneys for Defendant,
FRANK CHARLES YANEZ

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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

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ORDER
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Upon consideration of the foregoing Stipulation, and good cause appearing therefore,
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IT IS HEREBY ORDERED:
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1.

Defendant, FRANK CHARLES YANEZ is ordered to file his response to Plaintiff,

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UNIVERSAL SECURITY AND FIRE, INC.’s Complaint, including, but not limited to, any motions

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to dismiss, motions to compel arbitration, or motions related to personal jurisdiction, no later than

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July 5, 2017

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Dated: June 27, 2017
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Troy L. Nunley
United States District Judge

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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

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