Zorio v. Experian Information Solutions Inc et al

Filing 72

ORDER by Judge Lucy H. Koh granting 70 Stipulation (lhklc2, COURT STAFF) (Filed on 11/14/2012)

Case5:12-cv-00498-LHK Document70 Filed11/02/12 Page1 of 4

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Bryan Cave LLP
333 Market Street, 25th Floor
San Francisco, CA 94105

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BRYAN CAVE LLP
Daniel Rockey, California Bar No. 178604
Goli Mahdavi, California Bar No. 245705
David A. Owens, California Bar No. 273179
333 Market Street, 25th Floor
San Francisco, CA 94105
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]
[e-mail]

7 Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.
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UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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OAKLAND DIVISION
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12 TIMOTHY ZORIO, an individual,
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Plaintiff,

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v.

STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME TO
RESPOND TO FIRST AMENDED
COMPLAINT

15 EXPERIAN INFORMATION
SOLUTIONS, INC.; TRANS UNION
16 L.L.C; EQUIFAX INFORMATION
SERVICES, L.L.C., JPMORGAN CHASE
17 BANK, N.A.; SETERUS, INC. formerly
known as IBM LENDER BUSINESS
18 PROCESS SERVICES, INC.,
Defendants.

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110186.1

Case No.: CV12-00498 LHK

Judge: Honorable Lucy H. Koh
Date Action Filed: January 31, 2012
Trial Date:
Not Assigned

Case5:12-cv-00498-LHK Document70 Filed11/02/12 Page2 of 4

Defendant JPMorgan Chase Bank, N.A. (“Defendant”) and Plaintiff Timothy Zorio

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2 (“Plaintiff”) (Defendant and Plaintiff are referred to collectively herein as the “Parties”), by and
3 through their counsel of record, hereby stipulates as follows:
WHEREAS, Plaintiff filed a Complaint on January 31, 2012 in United States District

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WHEREAS, Defendant was served on Defendant on February 9, 2012; and

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WHEREAS, Defendant’s filed a Motion to Dismiss the Complaint on March 1, 2012; and

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WHEREAS, Defendant’s Motion to Dismiss the Complaint was granted with leave to

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Bryan Cave LLP
333 Market Street, 25th Floor
San Francisco, CA 94105

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WHEREAS, Plaintiff filed a First Amended Complaint was filed on October 22; and

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WHEREAS, pursuant to Court Order, Defendant’s responsive pleading is due on

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WHEREAS, Northern District of California Local Rule 6-2 (b) provides that the Court
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may extend the time for a party to respond;
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WHEREAS, the undersigned Parties stipulate to extend Defendant’s time to move against,
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answer, or otherwise respond to the Plaintiff’s First Amended Complaint be extended to
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December 10, 2012;
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WHEREAS, the Parties are engaged in settlement discussions to resolve this matter
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amicably, and the Parties agree that judicial economy and the interests of the Parties in avoiding
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unnecessary expenses would be best served and promoted by extending the time required for
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Defendants to respond to the First Amended Complaint;
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NOW, THEREFORE, the undersigned parties stipulate that the time for Defendant to
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move against, answer, or otherwise respond shall be extended to December 10, 2012;
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This stipulation is not a waiver by either of the Parties to this stipulation as to any rights,
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claims, nor defenses, including venue, as to this action. This stipulation may be executed in
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counterparts, including by signature, by facsimile, or electronically.
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110186.1

Case5:12-cv-00498-LHK Document70 Filed11/02/12 Page3 of 4

1 Dated: November 2, 2012
BRYAN CAVE LLP
Daniel Rockey
Goli Mahdavi
David A. Owens

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By: /s/ David A. Owens
Attorneys for Defendant
JPMorgan Chase Bank, N.A.

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Dated: November 2, 1012
STEBURG LAW FIRM
Anita L. Steburg

Bryan Cave LLP
333 Market Street, 25th Floor
San Francisco, CA 94105

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By: /s/ Anita L. Steburg
Attorneys for Plaintiff
Timothy Zorio

Case5:12-cv-00498-LHK Document70 Filed11/02/12 Page4 of 4

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[PROPOSED ORDER]

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Pursuant to the Stipulation to Extend Time to Respond to First Amended Complaint,

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IT IS HEREBY ORDERED THAT:

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1.

Defendant shall have until December 10, 2012 to file a response to Plaintiff’s First

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Bryan Cave LLP
333 Market Street, 25th Floor
San Francisco, CA 94105

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Amended Complaint.
November 14, 2012
Dated: __________________

_____________________________
Honorable Lucy H. Koh
United States District Judge