Vorobets v. NTT Data Federal Services

Filing 16

STIPULATION and ORDER signed by Chief District Judge Troy L. Nunley on 01/27/25 ORDERING NTT Data to file a responsive pleading within 5 days. (Deputy Clerk AJB)

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KEVIN JACKSON, CA Bar No. 278169 kjackson@foley.com 2 FOLEY & LARDNER LLP 11988 EL CAMINO REAL, SUITE 400 3 SAN DIEGO, CALIFORNIA 92130 TELEPHONE: 858.847.6700 4 FACSIMILE: 858.792.6773 1 5 6 7 8 9 10 11 12 Attorneys for Defendant NTT DATA FEDERAL SERVICES JILL P. TELFER, STATE BAR NO. 145450 LAW OFFICES OF JILL P. TELFER A PROFESSIONAL CORPORATION 980 9TH STREET SUITE 2550 SACRAMENTO, CALIFORNIA 95814 TELEPHONE: (916) 446-1916 FACSIMILE: (916) 446-1726 E-MAIL: jtelfer@telferlaw.com 13 Attorney for Plaintiff 14 MARK VOROBETS 15 UNITED STATES DISTRICT COURT 16 EASTERN DISTRICT OF CALIFORNIA 17 18 MARK VOROBETS, 19 20 21 22 23 24 Case No. 2:24-cv-01419-TLN-SCR Plaintiff, vs. NTT DATA FEDERAL SERVICS, and DOES 1 through 20, inclusive, Defendants. STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO PLAINTIFF’S FIRST AMENDED COMPLAINT (L.R. 144(A)) Complaint Filed: May 17, 2024 FAC Filed: December 13, 2024 Judge: Hon. Troy L. Nunley 25 26 27 28 STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S FAC Case No. 2:24-cv-01419-TLN-SCR 1 Plaintiff MARK VOROBETS (“Plaintiff”) and Defendant NTT DATA FEDERAL 2 SERVICES (“NTT Data”), by and through their undersigned counsel, and pursuant to Civil 3 Local Rule 144(a), respectfully submit this Joint Stipulation to Extend Time for NTT Data 4 to file an Answer, and no other responsive pleading, to Plaintiff’s First Amended 5 Complaint. 6 7 8 9 10 11 WHEREAS, Plaintiff filed his Complaint in the above-captioned action (the “Complaint”); WHEREAS, on May 21, 2024, Plaintiff caused the Complaint and Summons to be served on NTT Data; WHEREAS, pursuant to Rule 12 of the Federal Rules of Civil Procedure, NTT Data’s deadline for filing its response to the Complaint was June 11, 2024; 12 WHEREAS, Plaintiff and NTT Data stipulated to a 14-day extension of NTT 13 Data’s deadline to respond to the Complaint by answer and no other responsive pleading; 14 WHEREAS, on June 25, 2024, NTT Data filed an Answer to the Complaint; 15 WHEREAS, Plaintiff filed his First Amended Complaint in the above-captioned 16 17 18 19 action (the “FAC”) on December 13, 2024, WHEREAS, NTT Data’s deadline for filing its response to the FAC was December 27, 2024; WHEREAS, due to an administrative oversight, NTT Data’s Answer to the FAC 20 was not filed by the December 27, 2024 deadline. Plaintiff and NTT Data wish to 21 stipulate to an extension of NTT Data’s deadline to respond to the FAC by answer and no 22 other responsive pleading within 5 days of the Court approving this request; 23 24 25 26 WHEREAS, such stipulation does not alter the date of any event or deadline already fixed by Court order; WHEREAS, pursuant to Local Rule 144(a), the parties may seek an extension of time by stipulation with Court approval; 27 NOW, HEREBY, THE PARTIES STIPULATE AND AGREE that, pursuant to 28 Local Rule 144(a), NTT Data shall have up to 5 days to file and serve an answer and no STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S FAC -2Case No. 2:24-cv-01419-TLN-SCR 1 2 other responsive pleading to Plaintiff’s FAC following the Court’s approval. IT IS SO STIPULATED AND AGREED. 3 4 DATED: January 27, 2025 LAW OFFICE OF JILL P. TELFER 5 6 /s/ Jill P. Telfer JILL P. TELFER Attorneys for Plaintiff MARK VOROBETS 7 8 9 10 DATED: January 27, 2025 FOLEY & LARDNER LLP Kevin Jackson 11 12 /s/ Kevin Jackson Kevin Jackson Attorneys for Defendant NTT DATA FEDERAL SERVICES 13 14 15 16 17 * I attest that the other signatory listed, and on whose behalf this filing is submitted, 18 concurs in the filing content and has authorized this filing. 19 20 21 DATED: January 27, 2025 /s/ Kevin Jackson Kevin Jackson 22 23 24 25 26 27 28 STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S FAC -3Case No. 2:24-cv-01419-TLN-SCR 1 PURSUANT TO STIPULATION, IT IS SO ORDERED. 2 3 4 5 6 DATED: January 27, 2025 ____________________________ Troy L. Nunley Chief United States District Judge 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S FAC -4Case No. 2:24-cv-01419-TLN-SCR

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