Marble Bridge Funding Group, Inc v. Liquid Capital Exchange, Inc. et al

Filing 47

ORDER GRANTING 41 Stipulation filed by Liquid Capital Exchange, Inc., Liquid Capital of Colorado, Sol Roter, Bruce Dawson. The date on which Defendant Sol Roter's response to the Complaint is due is extended to the date on which Defendants' response to Plaintiff's Amended Complaint is due. Signed by Judge Edward J. Davila on 10/14/2015. (ecg, COURT STAFF) (Filed on 10/14/2015)

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DENIS F. SHANAGHER (SBN 100222)
[e-mail]
DUANE MORRIS LLP
Spear Street Tower
One Market Plaza, Suite 2200 DISTR
ICT
S
San Francisco, CA 94105-1127
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C
Telephone: [phone]
TA
Facsimile: [phone]

Attorneys for Defendants
Liquid Capital Exchange, Inc., BDB Capital, Inc.
(d/b/a Liquid Capital of Colorado)(erroneously
sued as Liquid Capital of Colorado), Sol Roter, an
Individual, and Bruce Dawson, an Individual
Attorneys for Plaintiff

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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UNITED STATES DISTRICT COURT

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Plaintiff;

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v.

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d wa
J u d ge E

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vila

E RDATED: 10/14/2015 C
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F
D IS T IC T O
R
Case No. 5:15-CV-00177-EJD
STIPULATION EXTENDING TIME TO
RESPOND TO COMPLAINT

LIQUID CAPITAL EXCHANGE, INC., LIQUID
CAPITAL OF COLORADO, SOL ROTER, AN
INDIVIDUAL, AND BRUCE DAWSON, AN
INDIVIDUAL,

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rd J . D a

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MARBLE BRIDGE FUNDING GROUP, INC.,

ERED

O ORD
IT IS S

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RT
U
O

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JON L. SWERGOLD (admitted pro hac vice)
[e-mail]
GREENBERG TRAURIG, LLP
401 East Las Olas Boulevard, Suite 2000
Fort Lauderdale, FL 33301
Telephone: [phone]
Facsimile: [phone]

R NIA

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LI

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Defendants.

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STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT
Case No. 5:15-CV-00177-EJD

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VINCENT P. HURLEY (SBN 111215)
[e-mail]
AMANDA COHEN (SBN 243946)
[e-mail]
RYAN THOMPSON (SBN 292281)
[e-mail]
LAW OFFICES OF VINCENT P. HURLEY
A Professional Corporation
28 Seascape Village
Aptos, CA 95003
Telephone: [phone]
Facsimile: [phone]

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WILLIAM J. GOINES (SBN: 61290)
[e-mail]
ALICE Y. CHU (SBN: 264990)
[e-mail]
GREENBERG TRAURIG, LLP
1900 University Avenue, Fifth Floor
East Palo Alto, California 94303
Telephone: [phone]
Facsimile: [phone]

UNIT
ED

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Pursuant to Civil L.R. 6-1, Defendant Sol Roter (“Mr. Roter”) and Plaintiff Marble Bridge

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Funding Group, Inc. (“Plaintiff”) (collectively “the Parties”), by their respective attorneys of record, in

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order to stipulate that Mr. Roter’s time to respond to Plaintiff’s Complaint is extended to the date on

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which Defendants’ response to Plaintiffs’ Amended Complaint is due, state as follows:

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WHEREAS, Plaintiff filed a Complaint for Damages on December 3, 2014;

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WHEREAS, on January 20, 2015, Defendants filed the following: (1) Motion to Dismiss for Lack

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of Personal Jurisdiction and Motion to Quash Service of Process [Dkt. No. 8]; and (2) Motion to Dismiss

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pursuant to Federal Rule of Civil Procedure 12(b)(6) [Dkt. No. 9];

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WHEREAS, on September 25, 2015, the Court issued an Order Granting in Part and Denying in

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Part Defendants’ Motion to Dismiss and Motion to Quash Re: Dkt. No. 8 [Dkt. No. 36], which granted

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Defendants’ motion as to Defendants BDB Capital, Inc. (sued as Liquid Capital of Colorado) and Bruce

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Dawson and denied the motion as to Mr. Roter;

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WHEREAS, on September 25, 2015, the Court issued an Order Granting Defendant’s Motion to

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Dismiss Re: Dkt. No. 9 [Dkt. No. 37], which dismissed all claims against Defendant Liquid Capital

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Exchange, Inc., with leave to amend;
WHEREAS, the Court’s September 25, 2015 Orders [Dkt. Nos. 36 and 37] require Plaintiff to file

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any amended complaint in response to the Orders on or before October 12, 2015;
WHEREAS, pursuant to Federal Rule of Civil Procedure Rule 12(a)(4), Mr. Roter’s pleading in

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response to Plaintiff’s Complaint is presently due on October 9, 2015;
WHEREAS, Plaintiff has advised Defendants that it intends on filing an Amended Complaint;

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and
WHEREAS, the Parties agree to extend the date on which Mr. Roter’s response to the Complaint

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is due to the date on which Defendants’ response to Plaintiff’s Amended Complaint is due.

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STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT
Case No. 5:15-CV-00177-EJD

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THEREFORE, IT IS HEREBY STIPULATED by and between the parties to the above-entitled

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action, through their respective counsel, that the date on which Defendant Sol Roter’s response to the

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Complaint is due is extended to the date on which Defendants’ response to Plaintiff’s Amended

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Complaint is due.

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DATED: October 8, 2015

GREENBERG TRAURIG, LLP

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By /s/ William J. Goines
William J. Goines
Jon L. Swergold

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Attorneys for Defendants Liquid Capital Exchange, Inc.,
BDB Capital, Inc. (d/b/a Liquid Capital of
Colorado)(erroneously sued as Liquid Capital of Colorado),
Sol Roter, an Individual, and Bruce Dawson, an Individual

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DATED: October 8, 2015

DUANE MORRIS LLP

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By /s/ Denis F. Shanagher
Denis F. Shanagher

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Attorneys for Plaintiff Marble Bridge Funding Group, Inc.

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STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT
Case No. 5:15-CV-00177-EJD

ATTESTATION CLAUSE

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I, William J. Goines, am the ECF User whose ID and password are being used to file this

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STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT. In compliance with Civil

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L.R. 5-1(i), I hereby attest that Denis F. Shanagher, attorney at Duane Morris LLP, concurred in this

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filing.

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DATED: October 8, 2015

GREENBERG TRAURIG, LLP

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By: /s/ William J. Goines
William J. Goines

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STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT
Case No. 5:15-CV-00177-EJD