Valente v. Equifax, Inc.

Filing 8

STIPULATION and ORDER signed by District Judge John A. Mendez on 5/9/2018 GRANTING an Extension of Time for Defendant to respond to complaint until 5/11/2018. (Hunt, G)

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THOMAS P. QUINN, JR. (SBN 132268)
NOKES & QUINN
410 Broadway, Suite 200
Laguna Beach, CA 92651
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Defendant EQUIFAX INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO DIVISION

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VANESSA VALENTE,

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Plaintiff,
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vs.
EQUIFAX INC.,
Defendant.

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Case No.: 2:18-cv-00496-JAM-CKD

SECOND STIPULATION TO EXTEND
TIME TO RESPOND TO COMPLAINT
AND ORDER
Complaint Served: March 14, 2018
Original Response Date: April 4, 2018
Current Response date: May 11, 2018
New Response Date: 30 Days from Filing of
Plaintiff’s First Amended Complaint

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Plaintiff VANESSA VALENTE (“Plaintiff”) and Defendant EQUIFAX INC.
(“Defendant”), hereby stipulate as follows:

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1. Plaintiff served Defendant on March 14, 2018.

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2. Defendant’s initial deadline to respond to the Complaint was April 4, 2018.

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3. Plaintiff and Defendant initially agreed to extend the time for Defendant to respond to

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the Complaint up to and including May 11, 2018, so that Defendant would have additional time

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to investigate this matter and the parties could explore the possibility of settlement. Accordingly,
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NOKES & QUINN
410 Broadway, Suite 200
Laguna Beach, CA 92651
[phone]

SECOND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT AND
[PROPOSED] ORDER

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on March 30, 2018, Defendant filed a stipulation between Plaintiff and Defendant to extend

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Defendant’s time to respond to the Complaint up to and including May 11, 2018 (docket # 6).

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4. On or about May 8, 2018, Plaintiff informed Defendant that she intended to file a First

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Amended Complaint. Accordingly, Plaintiff and Defendant agreed that Defendant’s deadline to

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answer, move, or otherwise respond to the Complaint should be further extended to 30 days from

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the filing date of the First Amended Complaint, and therefore Plaintiff and Defendant submit this

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second stipulation to extend time to respond to the Complaint.

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This change in response deadline will not alter the date of any event or any deadline
already fixed by Court order, local rules, or the Federal Rules of Civil Procedure.

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Respectfully submitted May 9, 2018:

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NOKES & QUINN
/s/ Thomas P. Quinn, Jr.
THOMAS P. QUINN, JR. (Bar No. 132268)
NOKES & QUINN
410 Broadway, Suite 200
Laguna Beach, CA 92651
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Defendant Equifax Inc.

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/s/ Elliot W. Gale
ELLIOT W. GALE (Bar No. 263326)
SAGARIA LAW, P.C.
3017 Douglas Blvd, Suite 200
Roseville, CA 95661
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff

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NOKES & QUINN
410 Broadway, Suite 200
Laguna Beach, CA 92651
[phone]

SECOND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT AND
[PROPOSED] ORDER

Signature Attestation

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I obtained the authorization of Elliot W. Gale to affix his signature to this stipulation and
submit this stipulation on his behalf.

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May 9, 2018

/s/ Thomas P. Quinn, Jr.
THOMAS P. QUINN, JR.

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ORDER

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Pursuant to stipulation, Defendant Equifax Inc. is granted a further extension to respond to
Plaintiff’s complaint until 30 days from the date that Plaintiff files her first amended complaint.

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IT IS SO ORDERED

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Dated: 5/9/2018

/s/ John A. Mendez______________
HONORABLE JOHN A. MENDEZ

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NOKES & QUINN
410 Broadway, Suite 200
Laguna Beach, CA 92651
[phone]

SECOND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT AND
[PROPOSED] ORDER