Perkins v. Experian Information Solutions, Inc. et al

Filing 17

ORDER EXTENDING TIME TO RESPOND TO COMPLAINT AND SETTING EXTENDED BRIEFING SCHEDULE ON ANY MOTION TO DISMISS. Defendant Experian Information Solutions, Inc. will answer or otherwise respond to the complaint no later than February 1, 2017. If Experian files a motion to dismiss the complaint, plaintiff shall oppose said motion no later than 30 days from the date upon which said motion is filed, and Experian shall file a reply no later than 21 days from the date upon which said opposition is filed. Signed by Judge Maxine M. Chesney on 12/6/16. (mmclc2, COURT STAFF) (Filed on 12/6/2016)

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Valerie McConnell (State Bar No. 274159)
[e-mail]
JONES DAY
Silicon Valley Office
1755 Embarcadero Road
Palo Alto, CA 94303
Telephone: [phone]
Facsimile:
+1.650.739.3900
Attorneys for Defendant
EXPERIAN INFORMATION SOLUTIONS, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JANET PERKINS,

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Plaintiff,
v.
EXPERIAN INFORMATION SOLUTIONS,
INC.; ET AL.,

Case No. 3:16-cv-06347-MMC
Assigned to: Judge Maxine M. Chesney
JOINT STIPULATION AND
[PROPOSED] ORDER FOR
EXTENSION OF TIME TO RESPOND
TO COMPLAINT

Defendants.

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Plaintiff Janet Perkins (“Plaintiff”) filed her Complaint in this action on November 1,

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2016 and served Defendant Experian Information Solutions (“Experian”) on November 22, 2016,

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at the same time that Plaintiff’s attorney served numerous other complaints on Experian. Given

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the large volume of complaints requiring a response from Experian at the same time, and in

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accordance with Local Rule 6-1(a), Plaintiff and Experian have agreed to an extension for

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Experian to answer or otherwise respond to the Complaint to February 1, 2017. To the extent that

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Experian files a motion to dismiss in this case, for the same considerations, Experian agrees that

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Plaintiff shall have 30 days to respond. Experian will thereupon have 21 days for any reply.

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Accordingly, IT IS HEREBY STIPULATED by and between Plaintiff and Experian, that

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the deadline for Experian to answer or otherwise respond to the Complaint is extended until

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February 1, 2017, Plaintiff’s deadline to respond to any motion to dismiss is extended to 30 days
JOINT STIPULATION AND [PROPOSED] ORDER FOR
EXTENSION OF TIME TO RESPOND TO COMPLAINT
Case No. 3:16-cv-06347-MMC

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from filing, and Experian’s deadline to reply in support of a motion to dismiss is extended to 21

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days from filing the opposition.

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Dated: December 5, 2016

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/s/ Elliot W. Gale
Elliot W. Gale (SBN 263326)
SAGARIA LAW, P.C.
2033 Gateway Place, 5th Floor
San Jose, CA 95110
Tele.: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff
Janet Perkins

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Dated: December 5, 2016

/s/ Valerie McConnell
Valerie McConnell (State Bar No. 274159)
JONES DAY
1755 Embarcadero Road
Palo Alto, CA 94303
Tele.: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendant
Experian Information Solutions, Inc.
ECF CERTIFICATION

I, Valerie McConnell, hereby attest pursuant to N.D. Cal. General Order No. 45 that the
concurrence to the filing of this document has been obtained from each signatory hereto.
Executed this 5th day of December, 2016, at Palo Alto, California.

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/s/ Valerie McConnell
Valerie McConnell (State Bar No. 274159)
JONES DAY
1755 Embarcadero Road
Palo Alto, CA 94303
Tele.: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendant
Experian Information Solutions, Inc.
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JOINT STIP AND [PROPOSED] ORDER FOR EXT OF
TIME TO RESPOND TO COMPLAINT
Case No. 3:16-cv-06347-MMC

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[PROPOSED] ORDER

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The Court, having considered the parties’ Joint Stipulation for Extension of Time to
extends
Inc.'s
Respond to the Complaint, hereby Extend Experian Information Solutions, Inc. deadline to

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answer or otherwise respond to the Complaint to February 1, 2017.

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PURSUANT TO THE STIPULATION, IT IS SO ORDERED. It is further ordered that, in

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the event a motion to dismiss is filed, the parties' proposed briefing schedule shall apply.

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December 6, 2016
DATED: ____________________________

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The Honorable Maxine M. Chesney
United States District Judge

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JOINT STIP AND [PROPOSED] ORDER FOR EXT OF
TIME TO RESPOND TO COMPLAINT
Case No. 3:16-cv-06347-MMC