Robey v. Toyota Motor Sales, U.S.A., Inc.

Filing 22

STIPULATION AND ORDER re 19 Concerning Time to File Amended Complaint and Response Thereto filed by Michael Robey. Motions terminated: 19 STIPULATION WITH PROPOSED ORDER Concerning Time to File Amended Complaint and Response Thereto filed by Michael Robey. Signed by Judge Edward M. Chen on 3/6/17. (bpfS, COURT STAFF) (Filed on 3/6/2017)

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GLANCY PRONGAY & MURRAY LLP
Lionel Z. Glancy (#134180)
Mark S. Greenstone (#199606)
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Attorneys for Plaintiff

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DYKEMA GOSSETT LLP
Tamara A. Bush (SBN 197153)
[e-mail]
John M. Thomas (SBN 266842)
[e-mail]
Abriami Gnandadesigan (SBN 263375)
[e-mail]
333 South Grand Avenue
Suite 2100
Los Angeles, CA 90071
Telephone: (213) 457 – 1800
Facsimile: (213) 457 -1850

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Attorneys for Defendant

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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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MICHAEL ROBEY, Individually and On
Behalf of a Class of Similarly Situated
Individuals,

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Plaintiff,
v.
TOYOTA MOTOR SALES, U.S.A., INC.,

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Case No. 3:16-cv-07212-EMC
Hon. Edward M. Chen
JOINT STIPULATION AND
[PROPOSED] ORDER CONCERNING
TIME TO FILE AMENDED
COMPLAINT AND RESPONSE
THERETO

Defendant.

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JOINT STIPULATION

Case No. 3:16-cv-07212-EMC

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Plaintiff Michael Robey (“Plaintiff”) and Defendant Toyota Motor Sales, U.S.A., Inc.

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(“Defendant”), hereby submit this Joint Stipulation and Proposed Order Concerning Time to

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File Amended Complaint and Response Thereto.

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WHEREAS, Plaintiff’s complaint was filed on December 16, 2016.
WHEREAS, Defendant filed a motion to dismiss the complaint on February 24, 2017.
WHEREAS, Plaintiff intends to file an amended complaint in lieu of responding to
Defendant’s motion to dismiss. Plaintiff’s amended complaint is due on March 17, 2017.
WHEREAS, the wife of Plaintiff’s counsel, Mark S. Greenstone, is expecting to
deliver on March 5, 2017. As a result, Mr. Greenstone anticipates being away from the office

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for the first half of March.
WHEREAS, Defendant’s counsel, Tamara A. Bush, has a prescheduled vacation from
April 9, 2017 through April 15, 2017.
WHEREAS, the parties have not previously requested an extension of time of time
from the Court.
IT IS THEREFORE STIPULATED AND AGREED BETWEEN THE PARTIES
THAT, subject to the Court’s approval:
1.

The date for Plaintiff to file an amended complaint shall be continued from

March 17, 2017 to April 7, 2017.
2.

Defendant’s response to Plaintiff’s amended complaint shall be filed on or

before May 12, 2017.

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JOINT STIPULATION

Case No. 3:16-cv-07212-EMC
-1353963.1 PRIUSHEADLIGHT

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Dated: March 3, 2017

GLANCY PRONGAY & MURRAY LLP

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By: s/ Mark S. Greenstone
Lionel Z. Glancy
Mark S. Greenstone
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Attorneys for Plaintiffs

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Dated: March 3, 2017

DYKEMA GOSSETT LLP

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By: s/ Tamara A. Bush
Tamara A. Bush (SBN 197153)
[e-mail]
John M. Thomas (SBN 266842)
[e-mail]
Abriami Gnandadesigan (SBN 263375)
[e-mail]
333 South Grand Avenue
Suite 2100
Los Angeles, CA 90071
Telephone: (213) 457 – 1800
Facsimile: (213) 457 -1850
Attorneys for Defendant

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General Order 45, Section X Certification

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The filing attorney hereby certifies that concurrence in the filing of the document has

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been obtained from each signatory, in accordance with N.D. Cal. Gen. Order 45, Section
X(B).

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*

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JOINT STIPULATION

Case No. 3:16-cv-07212-EMC
-2353963.1 PRIUSHEADLIGHT

[PROPOSED] ORDER

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Having reviewed the parties’ Joint Stipulation and Proposed Order Concerning Time

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to File Amended Complaint and Response Thereto, and good cause appearing, IT IS

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Defendant’s response to Plaintiff’s amended complaint shall be filed on or

before May 12, 2017.
3.

5/4/17 hearing on motion to dismiss is vacated.

S DISTRIC

3/6
Dated: _________________, 2017

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E
TC
_____________________________
AT
T The Edward M. Chen
United States District Judge

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RDERE
S SO O IED
IT I
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AS MO

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dwar
Judge E

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JOINT STIPULATION

Case No. 3:16-cv-07212-EMC
-3353963.1 PRIUSHEADLIGHT

en

d M. Ch

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2017 to April 7, 2017.

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The date for Plaintiff to file an amended complaint shall be continued from March 17,

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HEREBY ORDERED THAT:

UNIT
ED

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PROOF OF SERVICE BY ELECTRONIC POSTING

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I, the undersigned say:

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I am not a party to the above case, and am over eighteen years old. On March 3, 2017, I

4 served true and correct copies of the foregoing document, by posting the document electronically to
5 the ECF website of the United States District Court for the Northern District of California, for receipt
6 electronically by the parties listed on the Court’s Service List.
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I affirm under penalty of perjury under the laws of the United States of America that the

8 foregoing is true and correct. Executed on March 3, 2017 at Los Angeles, California.
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s/ Mark S. Greenstone
Mark S. Greenstone

CAND-ECF-

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3/3/2017 5:48 PM