Pandya v. Experian Information Solutions, Inc. et al

Filing 37

SECOND JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT. Signed by Judge Thelton E. Henderson on 1/10/2017. (tlS, COURT STAFF) (Filed on 1/12/2017)

1
2
3
4
5
6
7

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.

8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10

SAN FRANCISCO DIVISION

11
12

ARUN PANDYA,

13
14
15
16

Case No. 3:16-cv-06373-TEH
Plaintiff,

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

17

Assigned to: Thelton E. Henderson
SECOND JOINT STIPULATION AND
[PROPOSED] ORDER FOR
EXTENSION OF TIME TO RESPOND
TO COMPLAINT

18
19
20

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

21

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

22

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

23

Complaint by February 1, 2017.

24

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

25

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

26

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

27

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

28

thereupon have 21 days for any reply.
NAI-1502368826v2

SECOND JOINT STIPULATION FOR EXTENSION OF
TIME TO RESPOND TO COMPLAINT
Case No. 3:16-cv-06373-TEH

1

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

2

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

3

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

4

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

5

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

6

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

7

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

8

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

9

21 days from filing the opposition.

10
11

Dated: January 9, 2017

12
13
14
15

/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
Arun Pandya

16
17
18

Dated: January 9, 2017

19
20
21
22

/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.

23
24
25
26
27
28
NAI-1502368826v2

-2-

SECOND JOINT STIPULATION FOR EXTENSION OF
TIME TO RESPOND TO COMPLAINT
Case No. 3:16-cv-06373-TEH

ECF CERTIFICATION

1
2
3
4

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.

5
/s/ Valerie McConnell
Valerie McConnell (SBN 274159)
JONES DAY
1755 Embarcadero Road
Palo Alto, CA 94303
Tele.: [phone]
Fax: [phone]
Email: [e-mail]

6
7
8
9
10

Attorneys for Defendant
Experian Information Solutions, Inc.

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
NAI-1502368826v2

-3-

SECOND JOINT STIPULATION FOR EXTENSION OF
TIME TO RESPOND TO COMPLAINT
Case No. 3:16-cv-06373-TEH

[PROPOSED] ORDER

1
2

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

3

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

4

deadline to answer or otherwise respond to the Complaint to February 28, 2017. Plaintiff’s

5

deadline to respond to any motion to dismiss is extended to 30 days from filing, and Experian’s

6

deadline to reply in support of a motion to dismiss is extended to 21 days from filing the

7

opposition.

8

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

9
10

1/10/2017
DATED: __________________________

11

The Honorable Judge Thelton E. Henderson
UNITED STATES DISTRICT JUDGE

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
NAI-1502368826v2

[PROPOSED] ORDER GRANTING SECOND JOINT
STIP FOR EXT OF TIME TO RESP TO COMPLAINT
Case No. 3:16-cv-06373-TEH