Anderson v. Charles Schwab and Company, Inc.,

Filing 24

ORDER EXTENDING DEFENDANT'S TIME TO RESPOND TO COMPLAINT. Pursuant to the stipulation of the parties and good cause appearing, defendant must file a responsive pleading to the Third Amended Complaint no later than March 1, 2013. Given the limited nature of the amendments, however, said extension shall not constitute good cause to amend the Pretrial Preparation Order in any manner. Signed by Judge Maxine M. Chesney on February 1, 2013. (mmclc1, COURT STAFF) (Filed on 2/1/2013)

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Deborah J. Broyles (SBN 167681)
Email: [e-mail]
Tiffany Renee Thomas (SBN 239085)
Email: [e-mail]
REED SMITH LLP
101 Second Street, Suite 1800
San Francisco, CA 94105-3659
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Defendant
Charles Schwab & Co., Inc.

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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JACQUELINE ANDERSON,

No.: 3:12-cv-01682-MMC

Plaintiff,

STIPULATION AND [PROPOSED] ORDER
EXTENDING DEFENDANT CHARLES
SCHWAB & CO., INC.’S TIME TO
RESPOND TO COMPLAINT

vs.
CHARLES SCHWAB AND COMPANY, INC.,
and DOES 1 through 100, inclusive,
Defendants.

Hon. Maxine M. Chesney

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STIPULATION AND [PROPOSED] ORDER EXTENDING DEFENDANT
CHARLES SCHWAB & CO., INC.’S TIME TO RESPOND TO COMPLAINT
US_ACTIVE-111791462.1-TTHOMAS 01/28/2013 8:42 AM

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Plaintiff Jacqueline Anderson (“Plaintiff”) and Defendant Charles Schwab & Co., Inc.
(“Defendant”), by and through their undersigned counsel of record, hereby stipulate as follows:
WHEREAS, on January 11, 2013, the parties filed a Stipulation and [Proposed] Order
seeking leave for Plaintiff’s filing of a Third Amended Complaint [Doc 19];
WHEREAS, on January 15, 2013, this Court granted Plaintiff leave to file a Third Amended
Complaint [Doc. 20];

WHEREAS, the Third Amended Complaint contains 270 separate and distinct paragraphs;

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WHEREAS, Defendant intends to file an answer to the Third Amended Complaint;

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REED SMITH LLP

WHEREAS, on January 17, 2013, Plaintiff filed a Third Amended Complaint [Doc. 21];

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A limited liability partnership formed in the State of Delaware

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WHEREAS, Defendant will be unable to complete its Answer within the time frame

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provided by the Federal Rules of Civil Procedure;
WHEREAS, an extension of time will not affect the case management schedule for this
action; and
WHEREAS, the instant Stipulation and [Proposed] Order constitutes the parties’ first request
for a time modification in this action.

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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by Plaintiff and
Defendant that:

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Pursuant to this stipulation, the parties agree to continue Defendant’s deadline to file its

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responsive pleading to the Third Amended Complaint from January 31, 2013 to March 1, 2013.

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SO STIPULATED.

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DATED: January 28, 2013

REED SMITH, LLP

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By: /s/ Tiffany Renee Thomas
Deborah J. Broyles
Tiffany Renee Thomas
Attorneys for Defendant Charles Schwab & Co., Inc.

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-1STIPULATION AND [PROPOSED] ORDER EXTENDING DEFENDANT
CHARLES SCHWAB & CO., INC.’S TIME TO RESPOND TO COMPLAINT

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DATED: January 28, 2013

Law Offices of Murlene J. Randle

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By: /s/ Murlene J. Randle
Murlene J. Randle
Attorneys for Plaintiff Jacqueline Anderson

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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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ORDER

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Pursuant to the stipulation of the parties and good cause appearing, IT IS HEREBY

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ORDERED THAT Defendant Charles Schwab & Co., Inc. must file a responsive pleading to

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Plaintiff Jacqueline Anderson’s Third Amended Complaint no later than March 1, 2013. Given the
limited nature of the amendments, however, said extension shall not constitute good cause to amend
the Pretrial Preparation Order in any manner.

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IT IS SO ORDERED.
Dated: ____________
February 1, 2013

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_____________________________________
The Honorable Maxine Chesney
United States District Judge

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-2STIPULATION AND [PROPOSED] ORDER EXTENDING DEFENDANT
CHARLES SCHWAB & CO., INC.’S TIME TO RESPOND TO COMPLAINT