Hannon v. Loughlin et al
Filing
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STIPULATION AND ORDER re 16 STIPULATION WITH PROPOSED ORDER REGARDING EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO THE COMPLAINT filed by American Express Company. Signed by Judge Jon S. Tigar on February 22, 2018. (wsn, COURT STAFF) (Filed on 2/22/2018)
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David C. Brownstein (Cal. Bar No. 141929)
Farmer Brownstein Jaeger & Goldstein LLP
235 Montgomery Street, Suite 835
San Francisco, California 94104
Telephone: 415-962-2873
Facsimile: 415-520-5678
Local Counsel for Defendant American Express Company
Howard S. Zelbo (pro hac vice application forthcoming)
Roger A. Cooper (pro hac vice application forthcoming)
Cleary Gottlieb Steen & Hamilton LLP
One Liberty Plaza
New York, New York 10006
Telephone: 212-225-2000
Facsimile: 212-225-3999
Attorneys for Defendant American Express Company
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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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Plaintiff,
-against-
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STIPULATION AND PROPOSED
ORDER REGARDING EXTENSION OF
TIME TO ANSWER OR OTHERWISE
RESPOND TO THECOMPLAINT
American Express Company, et al.,
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Case No. 17-cv-07236-JST
George J. Hannon,
Defendants,
-andWells Fargo & Company,
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Nominal Defendant.
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Pursuant to Civil Local Rule 6-1, defendant American Express Company (“Defendant”)
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and plaintiff George J. Hannon (“Plaintiff”) hereby stipulate and agree with reference to
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the following:
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A.
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Plaintiff filed a complaint in this case against Defendant on December 20, 2017
(the “Complaint”).
STIPULATION AND PROPOSED ORDER REGARDING EXTENSION OF TIME TO ANSWER OR
OTHERWISE RESPOND TO THE COMPLAINT
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Case No. 17-cv-07236-JST
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B.
The Complaint was served on Defendant on December 28, 2017.
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C.
On January 16, 2018, Plaintiff and Defendant agreed to extend the time for
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Defendant to answer, move with respect to, or otherwise respond to the Complaint
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to February 20, 2018.
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D.
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On January 23, 2018, the Court scheduled a Case Management Conference for
March 28, 2018 at 2:00 p.m.
E.
Plaintiff and Defendant have now agreed to further extend the deadline for
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Defendant to answer, move with respect to, or otherwise respond to the Complaint
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by an additional 30 days to March 22, 2018.
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F.
In addition, to the extent Defendant moves to dismiss the Complaint, Plaintiff and
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Defendant agree to set (i) April 12, 2018 as the deadline for Plaintiff to file an
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opposition to Defendant’s motion to dismiss and (ii) May 3, 2018 as the deadline
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for Defendant to file a reply in further support of Defendant’s motion to dismiss.
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Terms of Stipulation
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The time for the Defendant to answer, move with respect to, or otherwise respond
to the Complaint shall be extended through and including March 22, 2018.
2.
To the extent Defendant moves to dismiss the Complaint, Plaintiff and Defendant
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shall comply with the following schedule: (i) April 12, 2018 as the deadline for
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Plaintiff to file an opposition to Defendant’s motion to dismiss; and (ii) May 3,
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2018 as the deadline for Defendant to file a reply in further support of Defendant’s
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motion to dismiss.
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IT IS SO STIPULATED.
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Dated: February 16, 2018
FARMER BROWNSTEIN JAEGER & GOLDSTEIN
LLP
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By: /s/ David C. Brownstein
David C. Brownstein
Attorney for Defendant
American Express Company
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STIPULATION AND PROPOSED ORDER REGARDING EXTENSION OF TIME TO ANSWER OR
OTHERWISE RESPOND TO THE COMPLAINT
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Case No. 17-cv-07236-JST
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Dated: February 16, 2018
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BOTTINI & BOTTINI, INC.
By: /s/ Albert Y. Chang
Albert Y. Chang
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Francis A. Bottini, Jr. (SBN 175783)
Albert Y. Chang (SBN 296065)
Yury A. Kolesnikov (SBN 271173)
7817 Ivanhoe Avenue, Suite 102
La Jolla, California 92037
Telephone:
(858) 914-2001
Facsimile:
(858) 914-2002
Email:
fbottini@bottinilaw.com
achang@bottinilaw.com
ykolesnikov@bottinilaw.com
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THE SHUMAN LAW FIRM
Kip B. Shuman (SBN 145842)
1 Montgomery Street, Suite 1800
San Francisco, California 94104
Telephone:
(303) 861-3003
Facsimile:
(303) 536-7849
Email:
kip@shumanlawfirm.com
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Attorney for Plaintiff
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ATTESTATION PURSUANT TO GENERAL ORDER 45
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I, David C. Brownstein, in compliance with General Order 45, Section X(B), hereby
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attest that I obtained the concurrence of all of the above-listed counsel in filing this
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document.
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/s/ David C. Brownstein
David C. Brownstein
Attorney for Defendant
American Express Company
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ORDER
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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Dated: February ___, 2018
________________________________
The Honorable Jon S. Tigar
United States District Judge
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STIPULATION AND PROPOSED ORDER REGARDING EXTENSION OF TIME TO ANSWER OR
OTHERWISE RESPOND TO THE COMPLAINT
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Case No. 17-cv-07236-JST
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