Simpson v. Experian Information Solutions, Inc. et al

Filing 11

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 6/4/18: The deadline for Defendant Credit One Bank, N.A. to respond to the Complaint shall be continued to June 21, 2018. (Kaminski, H)

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Tuan Uong (SBN 272447)
Email:
[e-mail]
REED SMITH LLP
355 South Grand Avenue
Suite 2900
Los Angeles, CA 90071-1514
Telephone: [phone]
Facsimile: [phone]

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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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Le T. Duong (SBN 297662)
Email:
[e-mail]
REED SMITH LLP
101 Second Street
Suite 1800
San Francisco, CA 94105-3659
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
Credit One Bank, N.A.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO DIVISION

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JOYCE SIMPSON,

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Case No. 2:18-cv-01166-TLN-KJN
Plaintiff,

v.

STIPULATION TO EXTEND DEFENDANT
CREDIT ONE BANK, N.A.’S TIME TO
RESPOND TO COMPLAINT AND ORDER

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Experian Information Solutions, Inc., LLC,;
19 Credit One Bank, N.A., and DOES 1 through 100
inclusive,
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Defendants.
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Compl. Filed:

May 9, 2018

Honorable Troy L. Nunley
Honorable Kendall J. Newman

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STIPULATION TO EXTEND DEFENDANT CREDIT ONE BANK, N.A.’S TIME TO
RESPOND TO COMPLAINT AND ORDER

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This Joint Stipulation to Extend Time to Respond to Complaint to June 21, 2018 is made by

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

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On May 10, 2018, Plaintiff served her Complaint on Credit One.

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Credit One’s response to Plaintiff’s Complaint is due on or before May 31, 2018.

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The parties agree to extend Credit One’s time to respond to the Complaint to June 21, 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

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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.
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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 June 21, 2018.
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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.
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THEREFORE, the parties stipulate as follows:

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STIPULATION

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The deadline for Credit One to respond to the Complaint shall be continued to June 21, 2018.

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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.
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STIPULATION TO EXTEND DEFENDANT CREDIT ONE BANK, N.A.’S TIME TO
RESPOND TO COMPLAINT AND ORDER

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IT IS SO STIPULATED.

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DATED: May 31, 2018

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REED SMITH LLP

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

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DATED: May 31, 2018

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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SAGARIA LAW, P.C.
By:

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/s/ Elliot Gale
Elliot Gale
[As authorized on May 31, 2018]
Attorney for Plaintiff
Joyce Simpson

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14 IT IS SO ORDERED.
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16 DATED: June 4, 2018
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Troy L. Nunley
United States District Judge

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–2–
STIPULATION TO EXTEND DEFENDANT CREDIT ONE BANK, N.A.’S TIME TO
RESPOND TO COMPLAINT AND ORDER