Howell v. IQ Data International, Inc.

Filing 20

FURTHER STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT. Signed by Judge Richard Seeborg on 1/5/17. (cl, COURT STAFF) (Filed on 1/5/2017)

1
2
3

JORDAN S. ALTURA (SBN: 209431)
GORDON & REES LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

4
5

Attorneys for Defendant
IQ DATA INTERNATIONAL INC.

6
7
8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10

Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

11

NIKKI HOWELL

12

Plaintiff,

13
14

vs.
IQ DATA INTERNATIONAL, INC.

15

Defendant.

)
)
)
)
)
)
)
)
)

CASE NO. 3:16-cv-05268-RS
FURTHER STIPULATION TO
EXTEND TIME TO RESPOND TO
COMPLAINT (L.R. 6-1(A)) AND
PROPOSED ORDER

16
17

TO THE HONORABLE COURT:

18

The parties hereto, Plaintiff Nikki Howell (“Plaintiff”) and Defendant IQ Data

19

International, Inc. (“IQ Data”), by and through their respective counsel of record, hereby

20

stipulate as follows:

21
22

WHEREAS, Plaintiff filed her Complaint on September 14, 2016, and IQ Data was
served with the Complaint on October 18, 2016.

23
24

WHEREAS, IQ Data’s current deadline to file a response to the Complaint is January 5,
2017.

25

WHEREAS, the parties are currently engaged in discussions regarding potential early

26

resolution of this matter and would like to complete such discussions before IQ Data is required

27

to respond to the Complaint, and believe they require an additional 30 days to do so.

28
-1Case No. 3:16-cv-05268-RS
FURTHER STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT
AND PROPOSED ORDER

1
2
3
4

WHEREAS, there has been two prior, 30-day extensions of time to respond to the
Complaint.
WHEREAS, Plaintiff and IQ Data do not anticipate that this extension of time will alter
the date of any event or any deadline already fixed by Court order.

5

IT IS HEREBY STIPULATED by and between Plaintiff and IQ Data through their

6

respective counsel of record that the deadline for IQ Data to respond is extended up to

7

February 6, 2017.

8

IT IS SO STIPULATED.

9
10

Dated: December 29, 2016

DELTA LAW GROUP

Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

11
By /s/ Jim G. Price
Jim G. Price
Attorneys for Plaintiff
NIKKI HOWELL

12
13
14
15
16

Dated: December 29, 2016

GORDON & REES LLP

17
By /s/ Jordan S. Altura
Jordan S. Altura
IQ DATA LIFE INSURANCE COMPANY

18
19
20
21
22
23
24

ATTESTATION OF E-FILED SIGNATURE
I, Jordan S. Altura, am the ECF user whose ID and password are being used to file this
Stipulation to Extend Time to Respond to Complaint. In compliance with Local Rule 5-1(i), I
hereby attest that Jim G. Price, counsel for Plaintiff Nikki Howell, has concurred in this filing.

25
Dated: December 29, 2016
26

/s/ Jordan S. Altura
Jordan S. Altura

27
28
-2Case No. 3:16-cv-05268-RS
FURTHER STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT
AND PROPOSED ORDER

1

IT IS SO ORDERED.

2
3
4
5

Dated: 1/5/17

__________________________________________
RICHARD SEEBORG
Judge of the United States District Court
Northern District of California

6
7
8
9
10

Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1125907/30961179v.1

-3Case No. 3:16-cv-05268-RS
FURTHER STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT
AND PROPOSED ORDER