Alexandra Polakovic v. Electronic Document Processing, Inc et al

Filing 11

ORDER GRANTING: 10 STIPULATION TO EXTEND TIME TO ANSWER INITIAL COMPLAINT, AND TO CONTINUE FRCP 26(f) AND ADR DEADLINES AND CASE MANAGEMENT CONFERENCE filed by Alexandra Polakovic. Case Management Statement due by 12/4/2014. Case Management Conference set for 12/11/2014 10:00 AM. Signed by Judge Maria-Elena James on 10/10/2014. (cdnS, COURT STAFF) (Filed on 10/10/2014)

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James A. Michel
State Bar No. 184730
2912 Diamond St. #373
San Francisco CA 94131
415/ 239-4949
(Fax [phone])
[e-mail]
Attorney for Plaintiff
ALEXANDRA POLAKOVIC

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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Case No. C 3:14-cv-03424 MEJ

ALEXANDRA POLAKOVIC, an
individual,

STIPULATION WITH PROPOSED
ORDER TO EXTEND TIME TO
ANSWER INITIAL COMPLAINT,
AND TO CONTINUE FRCP 26(f)
AND ADR DEADLINES AND CASE
MANAGEMENT CONFERENCE

Plaintiff,
v.
ELECTRONIC DOCUMENT
PROCESSING, INC., a California
corporation; PRESCOTT
WOODFORD, individually and in his
official capacity, et al.,

L.R. 6-2
Judge: Hon. Maria-Elena James
Ctrm : Courtroom B, 15th Floor
Loc’n : 450 Golden Gate Avenue
San Francisco CA 94102

Defendants.
_________________________/

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Pursuant to L.R. 6-2, Plaintiff, ALEXANDRA POLAKOVIC, and Defendants,

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ELECTRONIC DOCUMENT PROCESSING, INC. and PRESCOTT WOODFORD,

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stipulate to the following:

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1. Defendant ELECTRONIC DOCUMENT PROCESSING, INC. (“EDP”) was
served the summons, complaint and other documents on 9/18/2014;
2. Defendant PRESCOTT WOODFORD was served the summons, complaint
and other documents on 9/22/2014;

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STIPULATION TO EXTEND TIME TO ANSWER AND OTHER DEADLINES

3. Jonathan Blute of Murphy Pearson Bradley & Feeney was just retained to

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represent Defendants, and contacted James Michel, Attorney for Plaintiff, on

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10/7/2014;
4. The reason for the delay is that Defendants were clarifying various issues

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related to insurance coverage;

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5. EDP will take up the defense of WOODFORD as its employee;

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6. Because Counsel for Plaintiff mailed Notice of a Lawsuit and Request to

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Waive Service of Summons with the Waiver of Summons forms on 7/31/2014 to

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both defendants, and neither defendant returned the signed Waiver of Summons

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after more than thirty days, plaintiff was forced to engage registered process

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servers and incurred $100 for service of EDP and $105 for service of

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WOODFORD;
7. EDP has agreed to reimburse Plaintiff for charges incurred for service of

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defendants and will do so by sending a check in the amount of $205 made payable

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to Plaintiff’s counsel by 10/31/2014;
8. Counsel for Defendants has requested an extension of time until

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11/7/2014 to respond to the complaint;
9. Plaintiff has agreed to extend time for Defendants to respond to the initial

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complaint so long as the Court agrees and extends the FRCivP 26(f) and ADR

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Deadlines, and Initial Case Management Conference currently scheduled for

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10/30/2014;

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10. No previous agreements to extend time have been made;

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11. The requested time modification would require that the Court continue

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the deadlines and dates as listed in the Order Setting Initial Case Management

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Conference and ADR Deadlines accordingly;

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STIPULATION TO EXTEND TIME TO ANSWER AND OTHER DEADLINES

The Case Management Conference is CONTINUED to December 4, 2014
at 10:00 a.m.

All deadlines are adjusted accordingly.

October 10, 2014