Ortiz v. Experian Information Solutions, Inc. et al

Filing 16

STIPULATION and ORDER 15 signed by Senior Judge William B. Shubb on 5/25/2018 extending time for Defendant Credit One Bank, N.A. to Respond to Complaint by 5/30/2018. (Kirksey Smith, K)

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

1 Tuan Uong (SBN 272447)
Email:
[e-mail]
2 REED SMITH LLP
355 South Grand Avenue
3 Suite 2900
Los Angeles, CA 90071-1514
4 Telephone: [phone]
Facsimile: [phone]
5
Le T. Duong (SBN 297662)
[e-mail]
6 Email:
REED SMITH LLP
7 101 Second Street
Suite 1800
8 San Francisco, CA 94105-3659
Telephone: [phone]
9 Facsimile: [phone]
10 Attorneys for Defendant
Credit One Bank, N.A.
11
12

UNITED STATES DISTRICT COURT

13

EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO DIVISION

14
15

ROBERT ORTIZ,

16
17
18

Case No. 2:18-cv-00954-WBS-CKD
Plaintiff,

v.

Experian Information Solutions, Inc.; Equifax,
19 Inc.; Credit One Bank, N.A., Avant, Inc.,, and
DOES 1 through 100 inclusive,
20
Defendants.
21

STIPULATION TO EXTEND DEFENDANT
CREDIT ONE BANK, N.A.’S TIME TO
RESPOND TO COMPLAINT AND
[PROPOSED] ORDER
Compl. Filed:

April 17, 2018

Honorable William B. Shubb
Honorable Carolyn K. Delaney

22
23
24
25
26
27
28
STIPULATION TO EXTEND DEFENDANT CREDIT ONE BANK, N.A.’S TIME TO
RESPOND TO COMPLAINT AND [PROPOSED] ORDER

1

This Joint Stipulation to Extend Time to Respond to Complaint to May 30, 2018 is made by

2 and between Plaintiff Robert Ortiz (“Plaintiff”) and Defendant Credit One Bank, N.A. (“Credit
3 One”) through their respective counsel, in light of the following facts:
RECITALS

4
5

On April 20, 2018, Plaintiff served her Complaint on Credit One.

6

Credit One’s response to Plaintiff’s Complaint is due on or before May 25, 2018.

7

The parties agree to extend Credit One’s time to respond to the Complaint to May 30, 2018,

8 in order to give Credit One additional time to investigate Plaintiff’s claims and prepare a proper
9 response, and for the parties to potentially reach a resolution of this matter.

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10

There is good cause to extend Credit One’s response deadline because Credit One requires

11 additional time to investigate Plaintiff’s allegations and prepare a proper response, and the parties
12 require additional time to consider a resolution of this matter.
13

Pursuant to Civil Local Rule 144, Plaintiff and Credit One stipulate that Credit One’s time to

14 respond to Plaintiff’s Complaint is extended to May 30, 2018.
15

This change in deadline will not alter the date of any event or any deadline already fixed by

16 Court order, local rules, or the Federal Rules of Civil Procedure.
17

THEREFORE, the parties stipulate as follows:

18

STIPULATION

19

The deadline for Credit One to respond to the Complaint shall be continued to May 30, 2018.

20

This change in deadline will not alter the date of any event or any deadline already fixed by

21 the Court order, local rules, or the Federal Rules of Civil Procedure.
22

IT IS SO STIPULATED.

23
24
25
26
27
28
–1–
STIPULATION TO EXTEND DEFENDANT CREDIT ONE BANK, N.A.’S TIME TO
RESPOND TO COMPLAINT AND [PROPOSED] ORDER

1

DATED: May 25, 2018

2

REED SMITH LLP

3
By: /s/ Le Duong
Tuan Uong
Le T. Duong
Attorneys for Defendant
Credit One Bank, N.A.

4
5
6
7

DATED: May 25, 2018

8

By:

9

REED SMITH LLP

10
A limited liability partnership formed in the State of Delaware

SAGARIA LAW, P.C.
/s/ Elliot Gale
Elliot Gale
[As authorized on May 25, 2018]
Attorney for Plaintiff
Robert Ortiz

11
12 IT IS SO ORDERED.
13

Dated: May 25, 2018

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
–2–
STIPULATION TO EXTEND DEFENDANT CREDIT ONE BANK, N.A.’S TIME TO
RESPOND TO COMPLAINT AND [PROPOSED] ORDER