Orekoya v. H2 Marketing Consultants LLC, et al.,

Filing 12

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 1/19/23 ORDERING that Defendants H2 Marketing Consultants LLC and Heather Hellmann have until 1/31/23, to answer or otherwise respond to Plaintiff's initial Complaint. (Kastilahn, A)

Case 2:22-cv-01155-AC Document 12 Filed 01/19/23 Page 1 of 3

1
2
3
4
5
6
7

Brent M. Douglas, (CSB# 268277)
Ethan B. Shakoori, (CSB # 330753)
HAHN LOESER & PARKS LLP
600 West Broadway, Suite 1500
San Diego, California 92101
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendants H2 Marketing Consultants LLC and Heather Hellmann

Joshua H. Watson (CSB# 238058)
CLAYEO C. ARNOLD, APC
9 865 Howe Avenue
10 Sacramento, CA 95825
Telephone: [phone]
11 Facsimile: [phone]
[e-mail]
Hahn Loeser & Parks, LLP
One America Plaza
600 W. Broadway, Suite 1500
San Diego, CA 92101
Tel: [phone]  Fax: [phone]

8

12
13

Attorneys for Plaintiff Morayo Orekoya

14

UNITED STATES DISTRICT COURT

15

EASTERN DISTRICT OF CALIFORNIA

16
17

MORAYO OREKOYA, individually
and on behalf of similarly situated
employees
19
18

20
21

Plaintiff
vs.

22
23
24

H2 MARKETING CONSULTANTS
LLC, HEATHER HELLMANN
Defendants.

25
26

Case No. 2:22-CV-01155-AC
STIPULATION AND ORDER TO
EXTEND TIME FOR DEFENDANTS
H2 MARKETING CONSULTANTS
LLC AND HEATHER HELLMANN
TO FILE AN ANSWER OR
OTHERWISE RESPOND TO
PLAINTIFF’S INITIAL COMPLAINT
Judge: Hon. Allison Claire
Dept.: 26
Complaint Filed: July 1, 2022
Trial Date: TBD

27
28
1
2:22-CV-01155-AC
STIPULATION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT
14283813.1

Case 2:22-cv-01155-AC Document 12 Filed 01/19/23 Page 2 of 3

Plaintiff Morayo Orekoya (“Plaintiff”) and Defendants H2 Marketing

1

Hahn Loeser & Parks, LLP
One America Plaza
600 W. Broadway, Suite 1500
San Diego, CA 92101
Tel: [phone]  Fax: [phone]

2 Consultants LLC and Heather Hellmann (collectively “Defendants”) by and through
3

their undersigned counsel of record, hereby stipulate and request that Defendants

4

receive an extension to file and serve a response to Plaintiff’s initial Complaint on or

5

before January 31, 2023.

6

Local Rule 144(a) states, “[u]nless the filing date has been set by order of the

7

Court, an initial stipulation extending the time for no more than twenty-eight (28) days

8

to respond to a complaint […] may be filed without approval of the Court if the

9

stipulation is signed on behalf of all parties who have appeared in the action and are

10

affected by the stipulation. All other extensions of time must be approved by the

11

Court. No open extensions of time by stipulation of the parties will be recognized.”

12

Plaintiff commenced the above-entitled action by filing a complaint

13

(“Complaint”) on or about July 1, 2022. Plaintiff served the Complaint on Defendants

14

on or about November 15, 2022. After being served with the complaint, Defendants

15

requested, and Plaintiffs agreed to, additional time to retain counsel, have that counsel

16

evaluate the claims asserted in Plaintiff’s Complaint, and to respond to Plaintiff’s

17

Complaint.

18

Defendants retained counsel earlier this year to evaluate the claims asserted in

19

Plaintiff’s Complaint. Counsel for Defendants is concurrently filing an Appearance

20

of Counsel in the above-entitled matter. Further, Plaintiff and Defendant are currently

21

engaging in discussions as to the claims and defenses in this matter for purposes,

22

including, but not limited to, settlement. In these discussions, counsel for Defendants

23

requested, and counsel for Plaintiff consented, to additional time to for Defendants to

24

respond to Plaintiff’s Complaint.

25

///

26

///

27

///

28

///
2
2:22-CV-01155-AC
STIPULATION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT
14283813.1

Case 2:22-cv-01155-AC Document 12 Filed 01/19/23 Page 3 of 3

1

Plaintiff and Defendants stipulate and request that this Court allow Defendants

2 to respond to Plaintiff’s Complaint on or before January 31, 2023.
3
4

Dated: January 19, 2023

HAHN LOESER & PARKS LLP

5

By:

6
7
8
9
10

Dated: January 19, 2023

Hahn Loeser & Parks, LLP
One America Plaza
600 W. Broadway, Suite 1500
San Diego, CA 92101
Tel: [phone]  Fax: [phone]

11

/s/Brent M. Douglas
Brent M. Douglas
Attorney for Defendants
H2 Marketing Consultants LLC and
Heather Hellmann

CLAYEO C. ARNOLD, A PROFESSIONAL
LAW CORPORATION

12

By:

13
14

/s/Joshua H. Watson (as authorized on 01/18/23)

Joshua H. Watson
Attorney for Plaintiff Morayo Orekoya

15

ORDER

16
17

IT IS HEREBY ORDERED that Defendants H2 Marketing Consultants LLC

18 and Heather Hellmann have until January 31, 2023, to answer or otherwise respond to
19

Plaintiff Morayo Orekoya’s initial Complaint in this action.

20
21

DATED: January 19, 2023

22
23
24
25
26
27
28
3
2:22-CV-01155-AC
STIPULATION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT
14283813.1