Bartell v. Electronic Document Processing, Inc et al

Filing 11

STIPULATION AND ORDER extending time to respond to complaint signed by Magistrate Judge Elizabeth D. Laporte: granting 10 Stipulation. The time to respond to complaint is extended to 4/9/2015. The Case Management Conference is continued to 4/28/2015 at 3:00 PM in Courtroom E, 15th Floor, San Francisco. The Case Management Statement is due by 4/21/2015. (shyS, COURT STAFF) (Filed on 2/26/2015)

STEVEN B. SOLTMAN, ESQ. (SBN 108649)
STEVEN S. NIMOY, ESQ. (SBN 172310)
2 SOLTMAN, LEVITT, FLAHERTY & WATTLES LLP
2535 Townsgate Road, Suite 307
3 Westlake Village, California 91361
Telephone: [phone]
4 Facsimile: [phone]
E-mail: [e-mail]
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Attorneys for Defendants, ELECTRONIC
DOCUMENT PROCESSING, INC. and
JAY KATOFSKY

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION
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HEATHER BARTELL,
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Plaintiff,
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vs.

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ELECTRONIC DOCUMENT
PROCESSING, INC., A California
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individually and in his official capacity;
17 and DOES 1 through 10, inclusive
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Defendants.
_______________________________

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CASE NO: CV14-05501-EFL
STIPULATION TO EXTEND TIME
TO RESPOND TO COMPLAINT AND
TO CONTINUE FRCP 26(F) AND
ADR DEADLINES AND CASE
MANAGEMENT CONFERENCE;
[PROPOSED] ORDER THEREON
AS MODIFIED
[L.R. 6-2]
Current response date: March 3, 2015
New response date: April 9, 2015

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TO THE PARTIES HEREIN AND TO THE HONORABLE COURT:
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WHEREAS, Plaintiff agrees to give Defendants Electronic Document Processing, Inc.
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and Jay Katofsky extended time to respond to the First Amended Complaint filed on February
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24, 2015 pursuant to Local Rules of Court 6-2 requiring an extension of deadlines fixed by the
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Court.
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NOW, THEREFORE, IT IS HEREBY STIPULATED among the parties hereto, by and
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through their attorneys of record, James A. Michel, Esq. for the Plaintiff, and Steven S. Nimoy,
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Esq., for Defendants Electronic Document Processing, Inc. and Jay Katofsky, to the following:
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C:\Users\ybarras\AppData\Local\Temp\notes1A03DD\Stipulation for Extension of Time 02.24.15.wpd

STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT AND TO CONTINUE FRCP
26(F) AND ADR DEADLINES AND CASE MANAGEMENT CONFERENCE; [PROPOSED]
ORDER THEREON

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1. Based upon the filing of the First Amended Complaint, Defendants’ response thereto
is currently due on March 10, 2015.

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2. The parties wish to initiate informal settlement discussions. The parties believe that

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a thirty (30) day extension of time to respond to the complaint through April 9, 2015 will

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facilitate settlement discussions and increase the possibility that this case may be resolved

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quickly.

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3. The parties believe that an extension of the F.R.C.P. 26(f) and ADR deadlines, and

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a continuance of the Initial Case Management Conference currently scheduled for March 17,

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2015, would similarly facilitate resolution;

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

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5. The requested time modification would require that the Court continue the deadlines

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and dates as listed in the Order Setting Initial Case Management Conference and ADR

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Deadlines accordingly;

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6. Pursuant to the foregoing, the parties request that the Court extend Defendants’ time

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to file the response to the initial complaint to April 3, 2015 and that the Court cancel the Order

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Setting Initial Case Management Conference and ADR Deadlines and issue a new Order.

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IT IS SO STIPULATED.

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DATED: February 25, 2015

SOLTMAN, LEVITT, FLAHERTY & WATTLES
LLP

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By::

/s/ Steven S. Nimoy
STEVEN S. NIMOY, ESQ.
Attorneys for Defendants,
ELECTRONIC DOCUMENT PROCESSING,
INC. and JAY KATOFSKY

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C:\Users\ybarras\AppData\Local\Temp\notes1A03DD\Stipulation for Extension of Time 02.24.15.wpd

STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT AND TO CONTINUE FRCP
26(F) AND ADR DEADLINES AND CASE MANAGEMENT CONFERENCE; [PROPOSED]
ORDER THEREON
-2-

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DATED: February 25, 2015

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By::

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_/s/ James A. Michel
JAMES A. MICHEL, ESQ.
Attorney for Plaintiff,
HEATHER BARTELL

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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Defendant Electronic Document Processing, Inc. and Jay Katofsky’s time to respond to

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the complaint is extended to April 9, 2015. The Case Management Conference is continued

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to April 28, 2015 at 3:00 p.m. A case management statement must be filed no later than April

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21, 2015.

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DATED: February 26, 2015

___________________________________
Honorable Elizabeth D. Laporte
United States Magistrate Judge

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C:\Users\ybarras\AppData\Local\Temp\notes1A03DD\Stipulation for Extension of Time 02.24.15.wpd

STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT AND TO CONTINUE FRCP
26(F) AND ADR DEADLINES AND CASE MANAGEMENT CONFERENCE; [PROPOSED]
ORDER THEREON
-3-