Cristobal v. Experian Information Solutions, Inc. et al

Filing 34

STIPULATION AND ORDER RE 19 TO EXTEND BARCLAYS BANK OF DELAWARE'S TIME TO FILE RESPONSE IN SUPPORT OF MOTION TO DISMISS PLAINTIFF'S COMPLAINT. Signed by Judge Richard Seeborg on 1/25/17. (cl, COURT STAFF) (Filed on 1/25/2017)

1 Abraham J. Colman (SBN 146933)
Email:
[e-mail]
2 Raymond Y. Kim (SBN 251210)
[e-mail]
3 REED SMITH LLP
355 South Grand Avenue, Suite 2900
4 Los Angeles, CA 90071-1514
Telephone:[phone]
5 Facsimile: [phone]

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

6 Le T. Duong (SBN 297662)
[e-mail]
7 REED SMITH LLP
101 Second Street, Suite 1800
8 San Francisco, CA 94105-3659
Telephone: [phone]
9 Facsimile: [phone]
10 Attorneys for Defendant
Barclays Bank Delaware
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA - SAN JOSE DIVISION

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16 OLIVER CRISTOBAL,

Case No. 3:16-cv-06328-RS

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STIPULATION TO EXTEND BARCLAYS
BANK DELAWARE’S TIME TO FILE
RESPONSE IN SUPPORT OF MOTION TO
DISMISS PLAINTIFF’S COMPLAINT
AND [PROPOSED] ORDER

Experian Information Solutions, Inc.; Equifax,
20 Inc.; Credit First, National Association; Barclay’s
Bank Delaware and DOES 1 through 100
21 inclusive,

Date:
Time:
Place:

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Compl. Filed:

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Plaintiff,
v.

Defendants.

March 16, 2017
1:30 p.m.
Courtroom 3
November 1, 2016

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Honorable Judge Richard Seeborg

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[L.R. 6-2]

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28 Case No. 3:16-cv-06328-RS
JOINT STIPULATION TO EXTEND BARCLAYS BANK DELAWARE’S TIME TO FILE RESPONSE IN
SUPPORT OF MOTION TO DISMISS PLAINTIFF’S COMPLAINT AND [PROPOSED] ORDER

This Stipulation to Extend Time to File Response in support of Motion to Dismiss Complaint

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2 is made by and between Plaintiff Oliver Cristobal (“Plaintiff”) and Defendant Barclays Bank
3 Delaware (“Barclays”) (collectively the “Parties”) through their respective counsel, in light of the
4 following facts:
RECITALS

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On December 5, 2016, Barclays filed a Motion to Dismiss Plaintiff’s Complaint with a

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7 noticed hearing date of March 16, 2017;
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On December 19, 2016, Plaintiff filed an Opposition to Barclays’ Motion to Dismiss;

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Barclays’ Response in support of the Motion to Dismiss is due on or before December 27,

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 2016;
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The Parties have reached a settlement in this matter and are in the process of preparing the

12 settlement agreement;
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The Parties agree to extend Barclays’ time to file a Response in support of the Motion to

14 Dismiss by 30 days to January 26, 2017 so that the Parties can prepare and execute the settlement
15 agreement and file a Stipulation to Dismiss Barclays from this action with prejudice;
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This extension will not affect the scheduled hearing date for the Motion to Dismiss on March

17 16, 2017;
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There is good cause to grant this Joint Motion because the Parties require additional time to

19 prepare and execute the settlement agreement and file a Stipulation to Dismiss Barclays from this
20 action with prejudice within the next 30 days.
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28 Case No. 3:16-cv-06328-RS

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JOINT STIPULATION TO EXTEND BARCLAYS BANK DELAWARE’S TIME TO FILE RESPONSE IN
SUPPORT OF MOTION TO DISMISS PLAINTIFF’S COMPLAINT AND [PROPOSED] ORDER

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STIPULATION
Pursuant to Civil Local Rule 6-2, Plaintiff and Barclays stipulate and respectfully request that
Barclays’ deadline to file a Response in Support of the Motion to Dismiss be extended to Thursday,
January 26, 2017.

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DATED: December 27, 2016

REED SMITH LLP

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By:

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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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/s/ Le T. Duong
Le T. Duong
Attorney for Defendant
Barclays Bank Delaware
[e-mail]

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DATED: December 27, 2016

SAGARIA LAW, P.C.

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By: /s/ Elliot w. Gale
Elliot W. Gale
Attorney for Plaintiff
Oliver Cristobal

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28 Case No. 3:16-cv-06328-RS

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JOINT STIPULATION TO EXTEND BARCLAYS BANK DELAWARE’S TIME TO FILE RESPONSE IN
SUPPORT OF MOTION TO DISMISS PLAINTIFF’S COMPLAINT AND [PROPOSED] ORDER

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[PROPOSED] ORDER
PURSUANT TO THE STIPULATION, AND FOR GOOD CAUSE SHOWING, IT IS SO
ORDERED that Barclays Bank Delaware’s deadline to file a Response in support of the Motion to

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Dismiss Plaintiff Oliver Cristobal’s Complaint is extended to January 26, 2017.
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1/25/17
Dated: ______________________

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________________________________
The Honorable Richard Seeborg
United States District Judge

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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28 Case No. 3:16-cv-06328-RS

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JOINT STIPULATION TO EXTEND BARCLAYS BANK DELAWARE’S TIME TO FILE RESPONSE IN
SUPPORT OF MOTION TO DISMISS PLAINTIFF’S COMPLAINT AND [PROPOSED] ORDER