Rodriguez v. Experian Information Solutions, Inc. et al

Filing 57

STIPULATION AND ORDER re 55 STIPULATION WITH PROPOSED ORDER Joint Stipulation to Continue Hearing Date for Defendants Experian Information Solutions, Inc.'s and Equifax, Inc.'s Motion to Dismiss and [Proposed] Order filed by Experian Information Solutions, Inc., Set/Reset Deadlines as to 55 STIPULATION WITH PROPOSED ORDER Joint Stipulation to Continue Hearing Date for Defendants Experian Information Solutions, Inc.'s and Equifax, Inc.'s Motion to Di smiss and [Proposed] Order, 49 MOTION to Dismiss , 19 MOTION to Dismiss. Motion Hearing set for 6/29/2017 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Edward M. Chen. Signed by Judge Edward M. Chen on 4/24/17. (bpfS, COURT STAFF) (Filed on 4/24/2017)

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Ben C. Lee (State Bar No. 282177)
[e-mail]
JONES DAY
555 California Street, 26th Floor
San Francisco, CA 94104
Telephone:
+1.415.626.3939
Facsimile:
+1.415.875.5700
Attorneys for Defendant
EXPERIAN INFORMATION SOLUTIONS, INC.
[Additional counsel on signature page]

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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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MARCO RODRIGUEZ,

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

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JOINT STIPULATION TO CONTINUE
HEARING DATE FOR DEFENDANTS
EXPERIAN INFORMATION
SOLUTIONS, INC.’S AND EQUIFAX,
INC.’S MOTIONS TO DISMISS AND
[PROPOSED] ORDER
Date: April 27, 2017
Time: 1:30 PM
Courtroom: Courtroom 6, 17th Floor
The Honorable Edward M. Chen

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Case No. 3:16-cv-06380-EMC

Pursuant to Civil L.R. 6-1(a), Plaintiff Marco Rodriguez (“Plaintiff”) and Defendants
Experian Information Solutions, Inc. and Equifax, Inc., (collectively “Defendants”), through their
respective attorneys of record, hereby stipulate and agree as follows:
WHEREAS, the Court has a hearing on Defendants’ motions to dismiss on April 27, 2017
at 1:30 p.m.;
WHEREAS, Plaintiff and Defendants are currently in settlement negotiations; and
WHEREAS, Plaintiff and Defendants hereby stipulate to continue the April 27, 2017
hearing on Defendants’ motions to dismiss to June 29, 2017, at 1:30 p.m., to allow parties to

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JOINT STIPULATION TO CONTINUE MOTION
TO DISMISS HEARING
Case No. 3:16-cv-06380-EMC

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continue settlement negotiations; and
WHEREAS, this extension will not alter the date of any event or deadline fixed by Court
order, the Local Rules, or the Federal Rules of Civil Procedure.

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Dated: April 20, 2017

JONES DAY

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By: /s/ Benjamin C. Lee
Benjamin C. Lee

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Attorneys for Defendant
EXPERIAN INFORMATION SOLUTIONS,
INC.

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Dated: April 20, 2017

EQUIFAX, INC.

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By: /s/ Thomas P. Quinn
Thomas P. Quinn

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Attorneys For Defendant
EQUIFAX, INC.

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Dated: April 20, 2017

SAGARIA LAW P.C.

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By: /s/ Elliot W. Gale
Elliot Gale
Attorneys for Plaintiff
MARCO RODRIGUEZ

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ECF CERTIFICATION
I, Benjamin C. Lee, hereby attest pursuant to N.D. Cal. Civil. L.R. 5-1 that the
concurrence to the filing of this document has been obtained from each signatory hereto.

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/s/ Benjamin C. Lee
Benjamin C. Lee (SBN 282177)

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JOINT STIPULATION TO CONTINUE MOTION
TO DISMISS HEARING
Case No. 3:16-cv-06380-EMC

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[PROPOSED] ORDER]

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The Court, having considered the parties’ Joint Stipulation to continue Motion to Dismiss

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Hearing, hereby continues the hearing on Defendants Experian Information Solutions, Inc.’s and

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Equifax, Inc.’s motion to dismiss to June 29, 2017, at 1:30 p.m.

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PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

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Honorable Judge Edward M. Chen

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UNIT
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______________________________
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4/24/17
DATED: ____________________

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JOINT STIPULATION TO CONTINUE MOTION
TO DISMISS HEARING
Case No. 3:16-cv-06380-EMC

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CERTIFICATE OF SERVICE

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I, Benjamin C. Lee, declare:

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I am a citizen of the United States and employed in San Francisco, California. I am over

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the age of eighteen years and not a party to the within-entitled action. My business address is

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Jones Day, 555 California Street, 26th Floor, San Francisco, CA 94104. On April 20, 2017, I

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served a copy of the JOINT STIPULATION TO CONTINUE HEARING DATE FOR

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DEFENDANTS EXPERIAN INFORMATION SOLUTIONS, INC.’S AND EQUIFAX,

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INC.’S MOTIONS TO DISMISS by electronic transmission.

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I am familiar with United States District Court for the Northern District of California’s

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practice for collecting and processing electronic filings. Under that practice, documents are

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electronically filed with the court. The court’s CM/ECF system will generate a Notice of

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Electronic Filing (NEF) to the filing party, the assigned judge, and any registered users in the

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case. The NEF will constitute service of the document. Registration as a CM/ECF user

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constitutes consent to electronic service through the court’s transmission facilities. Under said

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practice, the following CM/ECF users were served:

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

Elliot Gale
[e-mail]

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Thomas Patrick Quinn, Jr.
[e-mail]

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Alisa A. Givental
[e-mail]

Executed on April 20, 2017, at San Francisco, California.
/s/ Benjamin C. Lee
Benjamin C. Lee

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JOINT STIPULATION TO CONTINUE MOTION
TO DISMISS HEARING
Case No. 3:16-cv-06380-EMC