Otero v. Experian Information Solutions, Inc. et al

Filing 13

STIPULATION AND ORDER re 12 STIPULATION WITH PROPOSED ORDER for Extension of Time to Respond to Complaint filed by Experian Information Solutions, Inc. Signed by Judge Edward M. Chen on 3/6/17. (bpfS, COURT STAFF) (Filed on 3/6/2017)

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Benjamin C. Lee (SBN 282177)
[e-mail]
JONES DAY
555 California Street, 26th Floor
San Francisco, CA 94104
Telephone:
[phone]
Facsimile:
[phone]

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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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EARLENE OTERO,

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

Case No. 3:17-cv-00508-EMC
Assigned to: Judge Edward M. Chen
JOINT STIPULATION AND
[PROPOSED] ORDER FOR
EXTENSION OF TIME TO RESPOND
TO COMPLAINT

Defendants.

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JOINT STIPULATION AND [PROPOSED] ORDER FOR
EXTENSION OF TIME TO RESPOND TO COMPLAINT
Case No. 3:17-cv-00508-EMC

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On January 31, 2017, Plaintiff Earlene Otero (“Plaintiff”) filed a Complaint in this action.

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Given the large volume of Complaints requiring a response from Defendant Experian Information

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Solutions, Inc. (“Experian”) at the same time, and in accordance with Local Rule 6-1(a), Plaintiff

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and Experian agree to an extension for Experian to answer or otherwise respond to the Complaint.

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Experian’s response to the Complaint is due April 3, 2017. To the extent that Experian files a

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

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

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3, 2017. Plaintiff’s deadline to respond to any motion to dismiss is extended to 30 days from

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

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from filing the opposition.

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Dated: March 2, 2017

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Attorneys for Plaintiff
Earlene Otero

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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]

Dated: March 2, 2017

/s/ Benjamin C. Lee
Benjamin C. Lee (SBN 282177)
JONES DAY
555 California Street, 26th Floor
San Francisco, CA 94104
Telephone:
[phone]
Facsimile:
[phone]
Email: [e-mail]
Attorneys for Defendant
Experian Information Solutions, Inc.

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JOINT STIPULATION AND [PROPOSED] ORDER FOR
EXTENSION OF TIME TO RESPOND TO COMPLAINT
Case No. 3:17-cv-00508-EMC

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ECF CERTIFICATION
I, Benjamin C. Lee, hereby attest pursuant to Local Rule 5-1(i)(3) that the concurrence to

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the filing of this document has been obtained from each signatory hereto.

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Executed on March 2, 2017, at San Francisco, California.

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/s/ Benjamin C. Lee
Benjamin C. Lee (SBN 282177)
JONES DAY
Attorneys for Defendant
Experian Information Solutions, Inc.

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JOINT STIPULATION AND [PROPOSED] ORDER FOR
EXTENSION OF TIME TO RESPOND TO COMPLAINT
Case No. 3:17-cv-00508-EMC

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[PROPOSED] ORDER

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

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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 April 3, 2017. Plaintiff’s deadline to

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

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

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PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

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The Honorable Judge Edward M. Chen

UNIT
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3/6/17
DATED: __________________________

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[PROPOSED] ORDER FOR EXTENSION OF TIME TO
RESPOND TO COMPLAINT
Case No. 3:17-cv-00508-EMC