Hannon v. Loughlin et al

Filing 17

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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1 2 3 4 5 6 7 8 9 10 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 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 SAN FRANCISCO DIVISION 14 15 16 17 Plaintiff, -against- 20 STIPULATION AND PROPOSED ORDER REGARDING EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO THECOMPLAINT American Express Company, et al., 18 19 Case No. 17-cv-07236-JST George J. Hannon, Defendants, -andWells Fargo & Company, 21 Nominal Defendant. 22 23 24 Pursuant to Civil Local Rule 6-1, defendant American Express Company (“Defendant”) 25 and plaintiff George J. Hannon (“Plaintiff”) hereby stipulate and agree with reference to 26 the following: 27 A. 28 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 1 Case No. 17-cv-07236-JST 1 B. The Complaint was served on Defendant on December 28, 2017. 2 C. On January 16, 2018, Plaintiff and Defendant agreed to extend the time for 3 Defendant to answer, move with respect to, or otherwise respond to the Complaint 4 to February 20, 2018. 5 D. 6 7 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 8 Defendant to answer, move with respect to, or otherwise respond to the Complaint 9 by an additional 30 days to March 22, 2018. 10 F. In addition, to the extent Defendant moves to dismiss the Complaint, Plaintiff and 11 Defendant agree to set (i) April 12, 2018 as the deadline for Plaintiff to file an 12 opposition to Defendant’s motion to dismiss and (ii) May 3, 2018 as the deadline 13 for Defendant to file a reply in further support of Defendant’s motion to dismiss. 14 15 Terms of Stipulation 1. 16 17 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 18 shall comply with the following schedule: (i) April 12, 2018 as the deadline for 19 Plaintiff to file an opposition to Defendant’s motion to dismiss; and (ii) May 3, 20 2018 as the deadline for Defendant to file a reply in further support of Defendant’s 21 motion to dismiss. 22 IT IS SO STIPULATED. 23 Dated: February 16, 2018 FARMER BROWNSTEIN JAEGER & GOLDSTEIN LLP 24 25 26 27 By: /s/ David C. Brownstein David C. Brownstein Attorney for Defendant American Express Company 28 STIPULATION AND PROPOSED ORDER REGARDING EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO THE COMPLAINT 2 Case No. 17-cv-07236-JST 1 2 Dated: February 16, 2018 3 BOTTINI & BOTTINI, INC. By: /s/ Albert Y. Chang Albert Y. Chang 4 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 5 6 7 8 9 10 11 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 12 13 14 15 Attorney for Plaintiff 16 17 ATTESTATION PURSUANT TO GENERAL ORDER 45 18 I, David C. Brownstein, in compliance with General Order 45, Section X(B), hereby 19 attest that I obtained the concurrence of all of the above-listed counsel in filing this 20 document. 21 /s/ David C. Brownstein David C. Brownstein Attorney for Defendant American Express Company 22 23 ORDER 24 25 26 27 PURSUANT TO STIPULATION, IT IS SO ORDERED. 22 Dated: February ___, 2018 ________________________________ The Honorable Jon S. Tigar United States District Judge 28 STIPULATION AND PROPOSED ORDER REGARDING EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO THE COMPLAINT 3 Case No. 17-cv-07236-JST

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