Ramirez v. Trans Union, LLC

Filing 10

ORDER granting 9 STIPULATION To Further Extend Time For Defendant TransUnion LLC To Respond To Initial Complaint filed by Trans Union, LLC. Signed by Magistrate Judge Jacqueline Scott Corley on 3/30/2012. (ahm, COURT STAFF) (Filed on 3/30/2012)

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STROOCK & STROOCK & LAVAN LLP
JULIA B. STRICKLAND (State Bar No. 83013)
STEPHEN J. NEWMAN (State Bar No. 181570)
BRIAN C. FRONTINO (State Bar No. 222032)
JEFFREY B. BELL (State Bar No. 269648)
2029 Century Park East
Los Angeles, CA 90067-3086
Telephone: [phone]
Facsimile: 310-556-5959
Email: [e-mail]

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Attorneys for Defendant
TRANSUNION LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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SERGIO L. RAMIREZ, on behalf of himself
and all others similarly situated,

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Plaintiff,
v.
TRANS UNION, LLC,

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Defendant.
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Case No. 3:12-cv-00632-JSC
STIPULATION TO FURTHER EXTEND
TIME FOR DEFENDANT TRANSUNION
LLC TO RESPOND TO INITIAL
COMPLAINT

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LA 51527509

STIPULATION TO FURTHER EXTEND TIME FOR DEFENDANT
TRANSUNION LLC TO RESPOND TO INITIAL COMPLAINT
Case No. 3:12-cv-00632-JSC

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WHEREAS, on February 9, 2012, plaintiff Sergio Ramirez (“Plaintiff”) filed the class

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action complaint in this action (the “Complaint”) against TransUnion LLC (“TransUnion”), which

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Complaint was served on TransUnion on February 16, 2012;

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WHEREAS, pursuant to Federal Rule of Civil Procedure 12(a), TransUnion’s initial time to
respond to the Complaint was March 8, 2012;

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WHEREAS, pursuant to Local Rule 6-1(a), parties may stipulate in writing, without court

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order, to extend the time within which to answer or otherwise respond to the complaint, provided

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the change will not alter the date of any event or any deadline already fixed by Court order;

2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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WHEREAS, the parties previously agreed to extend the deadline for TransUnion to respond
to the Complaint to and including March 29, 2012;
WHEREAS, due to the absence of key TransUnion personnel, TransUnion has requested,

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and Plaintiff has agreed, to further extend the deadline for TransUnion to answer or otherwise

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respond to the Complaint to and including April 6, 2012; and

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WHEREAS, the further extension proposed herein will not alter the date of any event or
any deadline already fixed by Court order;
IT IS HEREBY STIPULATED by and between the parties, through their respective counsel

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of record, that TransUnion’s time to answer or otherwise respond to the Complaint is extended to

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and including April 6, 2012.

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Dated: March 29, 2012

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STROOCK & STROOCK & LAVAN LLP
JULIA B. STRICKLAND
STEPHEN J. NEWMAN
BRIAN C. FRONTINO

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By:

/s/ Jeffrey B. Bell
Jeffrey B. Bell

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Attorneys for Defendant
TRANSUNION LLC

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LA 51527509

-1STIPULATION TO FURTHER EXTEND TIME FOR DEFENDANT
TRANSUNION LLC TO RESPOND TO INITIAL COMPLAINT
Case No. 3:12-cv-00632-JSC

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Dated: March 29, 2012

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ANDERSON, OGILVIE & BREWER, LLP
ANDREW J. OGILVIE
CAROL MCLEAN BREWER

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By:

/s/ Andrew J. Ogilvie
Andrew J. Ogilvie

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Attorneys for Plaintiff
SERGIO L. RAMIREZ

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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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LA 51527509

-2STIPULATION TO FURTHER EXTEND TIME FOR DEFENDANT
TRANSUNION LLC TO RESPOND TO INITIAL COMPLAINT
Case No. 3:12-cv-00632-JSC

DECLARATION OF JEFFREY B. BELL

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I, Jeffrey B. Bell, hereby declare as follows:

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I am admitted to practice before this Court and am an associate at Stroock &

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Stroock & Lavan LLP (“Stroock”), counsel for defendant TransUnion LLC (“TransUnion”) in this

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action. I submit this Declaration in support of the Stipulation to Further Extend Time for

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TransUnion to Respond to Initial Complaint (the “Stipulation”), in accordance with Section X.B. of

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General Order 45 of this Court. The facts set forth herein are true of my own personal knowledge.

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If called as a witness, I could and would competently testify thereto.
2.

On March 29, 2012, Andrew J. Ogilvie, counsel for plaintiff Sergio L. Ramirez, sent

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me an e-mail approving the content of the Stipulation, which I drafted and sent to him for his

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review and approval on March 28, 2012, and authorizing me to execute it on his behalf.

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I declare under the penalty of perjury under the laws of the United States of America that
the foregoing is true and correct. Executed this 29th day of March, 2012.

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/s/ Jeffrey B. Bell
Jeffrey B. Bell

Dated: 3/30/2012

S DISTRICT
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NO

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TED

GRAN

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cquelin

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Corley

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Judge Ja

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R NIA

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UNIT
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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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D IS T IC T O
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LA 51527509

-3STIPULATION TO FURTHER EXTEND TIME FOR DEFENDANT
TRANSUNION LLC TO RESPOND TO INITIAL COMPLAINT
Case No. 3:12-cv-00632-JSC