Perkins v. Experian Information Solutions, Inc. et al

Filing 30

SECOND 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 28, 20 17. 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 01/10/17. (mmclc2, COURT STAFF) (Filed on 1/10/2017)

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Valerie McConnell (SBN 274159)
[e-mail]
JONES DAY
Silicon Valley Office
1755 Embarcadero Road
Palo Alto, CA 94303
Telephone:
+1.650.739.3939
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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SAN FRANCISCO DIVISION

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JANET PERKINS,

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

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

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On November 1, 2016, Plaintiff Janet Perkins (“Plaintiff”) filed a Complaint in this action,

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one of many Complaints filed by Plaintiff’s counsel on the same day. Shortly thereafter, Plaintiff

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and Experian agreed to an extension for Experian to answer or otherwise respond to the

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Complaint by February 1, 2017.

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In accordance with Local Rule 6-1(a), Plaintiff and Experian now agree to a second

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extension for Experian to answer or otherwise respond to the Complaint. Experian’s response to

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Plaintiff’s Complaint is due February 28, 2017. To the extent that Experian files a motion to

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dismiss in this case, Experian agrees that Plaintiff shall have 30 days to respond. Experian will

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thereupon have 21 days for any reply.
NAI-1502368830v2

SECOND JOINT STIPULATION FOR EXTENSION OF
TIME TO RESPOND TO COMPLAINT
Case No. 3:16-cv-06347-MMC

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This further extension is necessary given Experian’s pending motion to consolidate this

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case with the many other cases filed by Plaintiff’s counsel, as well as Experian’s pending motions

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to dismiss numerous other Complaints filed by Plaintiff’s counsel, which raise legal issues that

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are identical to the ones presented by Plaintiff’s Complaint.

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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 28, 2017. Plaintiff’s deadline to respond to any motion to dismiss is extended to 30

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

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21 days from filing the opposition.

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Dated: January 9, 2017

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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: January 9, 2017

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/s/ Valerie McConnell
Valerie McConnell (SBN 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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NAI-1502368830v2

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SECOND JOINT STIPULATION FOR EXTENSION OF
TIME TO RESPOND TO COMPLAINT
Case No. 3:16-cv-06347-MMC

ECF CERTIFICATION

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I, Valerie McConnell, hereby attest pursuant to Local Rule 5-1(i)(3) that the concurrence
to the filing of this document has been obtained from each signatory hereto.
Executed this 9th day of January, 2017, at Palo Alto, California.

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/s/ Valerie McConnell
Valerie McConnell (SBN 274159)
JONES DAY
1755 Embarcadero Road
Palo Alto, CA 94303
Tele.: [phone]
Fax: [phone]
Email: [e-mail]

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Attorneys for Defendant
Experian Information Solutions, Inc.

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NAI-1502368830v2

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SECOND JOINT STIPULATION FOR EXTENSION OF
TIME TO RESPOND TO COMPLAINT
Case No. 3:16-cv-06347-MMC

[PROPOSED] ORDER

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The Court, having considered the parties’ Second Joint Stipulation for Extension of Time

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to Respond to the Complaint, hereby extends Experian Information Solutions, Inc.’s (“Experian”)

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deadline to answer or otherwise respond to the Complaint to February 28, 2017. Plaintiff’s
of said motion
deadline to respond to any motion to dismiss is extended to 30 days from filing, and Experian’s
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deadline to reply in support of a motion to dismiss is extended to 21 days from filing the

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opposition.

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PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

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January 10, 2017
DATED: __________________________

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The Honorable Judge Maxine M. Chesney
UNITED STATES DISTRICT JUDGE

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NAI-1502368830v2

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