Vorobets v. NTT Data Federal Services
Filing
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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)
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
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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
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Attorney for Plaintiff
14 MARK VOROBETS
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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MARK VOROBETS,
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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
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STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S FAC
Case No. 2:24-cv-01419-TLN-SCR
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Plaintiff MARK VOROBETS (“Plaintiff”) and Defendant NTT DATA FEDERAL
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SERVICES (“NTT Data”), by and through their undersigned counsel, and pursuant to Civil
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Local Rule 144(a), respectfully submit this Joint Stipulation to Extend Time for NTT Data
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to file an Answer, and no other responsive pleading, to Plaintiff’s First Amended
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Complaint.
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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;
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WHEREAS, Plaintiff and NTT Data stipulated to a 14-day extension of NTT
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Data’s deadline to respond to the Complaint by answer and no other responsive pleading;
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WHEREAS, on June 25, 2024, NTT Data filed an Answer to the Complaint;
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WHEREAS, Plaintiff filed his First Amended Complaint in the above-captioned
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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
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was not filed by the December 27, 2024 deadline. Plaintiff and NTT Data wish to
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stipulate to an extension of NTT Data’s deadline to respond to the FAC by answer and no
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other responsive pleading within 5 days of the Court approving this request;
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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;
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NOW, HEREBY, THE PARTIES STIPULATE AND AGREE that, pursuant to
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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
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other responsive pleading to Plaintiff’s FAC following the Court’s approval.
IT IS SO STIPULATED AND AGREED.
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DATED: January 27, 2025
LAW OFFICE OF JILL P. TELFER
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/s/ Jill P. Telfer
JILL P. TELFER
Attorneys for Plaintiff MARK VOROBETS
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DATED: January 27, 2025
FOLEY & LARDNER LLP
Kevin Jackson
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/s/ Kevin Jackson
Kevin Jackson
Attorneys for Defendant NTT DATA
FEDERAL SERVICES
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* I attest that the other signatory listed, and on whose behalf this filing is submitted,
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concurs in the filing content and has authorized this filing.
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DATED: January 27, 2025
/s/ Kevin Jackson
Kevin Jackson
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STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S FAC
-3Case No. 2:24-cv-01419-TLN-SCR
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED: January 27, 2025
____________________________
Troy L. Nunley
Chief United States District Judge
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STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S FAC
-4Case No. 2:24-cv-01419-TLN-SCR
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