Mujadadi-Turan v. Motorola Mobility, LLC et al

Filing 45

ORDER GRANTING 44 Stipulation to Continue Deadline for Defendants to Respond filed by Metropolitan Life Insurance Company. Response due 4/4/2016. Signed by Judge Edward J. Davila on 3/9/2016. (ecg, COURT STAFF) (Filed on 3/9/2016)

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UNITED STATES DISTRICT COURT

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Counsel Appear On The Following Page

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S DISTRICT
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NORTHERN DISTRICT OF CALIFORNIA

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NIA MUJADADI-TURAN
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Plaintiff,
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vs.

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MOTOROLA MOBILITY, LLC;
METROPOLITAN LIFE INSURANCE
COMPANY

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Defendants.

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Case No.: 05:15-cv-2752-EJD
Hon. Edward J. Davila
JOINT STIPULATION TO CONTINUE
DEADLINE FOR DEFENDANTS TO
RESPOND TO PLAINTIFF’S
COMPLAINT
Complaint Filed:
Trial Date:

June 18, 2015
TBD

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JOINT STIPULATION TO CONTINUE DEADLINE FOR DEFENDANTS TO RESPOND TO
PLAINTIFF’S COMPLAINT

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GLENN KANTOR (SBN 122643)
[e-mail]
BETH A. DAVIS (SBN 277560)
[e-mail]
ANDREW KANTOR (SBN 303093)
[e-mail]
KANTOR & KANTOR, LLP
19839 Nordhoff Street
Northridge, CA 91324
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiff,
NIA MUJADADI-TURAN
C. ANDREW KITCHEN (SBN 292609)
[e-mail]
LINDA B. OLIVER (SBN 166720)
[e-mail]
ALEXANDRA V. DRURY (SBN 291920)
[e-mail]
MAYNARD, COOPER, & GALE, LLP
600 Montgomery Street, Suite 2600
San Francisco, CA 94111
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
METROPOLITAN LIFE INSURANCE COMPANY
BENJAMIN A. EMMERT (SBN 212157)
[e-mail]
LITTLER MENDELSON, P.C.
A Professional Corporation
50 West San Fernando Street, 15th Floor
San Jose, CA 95113
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
MOTOROLA MOBILITY, LLC

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JOINT STIPULATION TO CONTINUE DEADLINE FOR DEFENDANTS TO RESPOND TO
PLAINTIFF’S COMPLAINT

{03561257.1}

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JOINT STIPULATION

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Pursuant to Civil Local Rule 6-1, Plaintiff Nia Mujadadi-Turan (“Plaintiff”) and

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Defendants Motorola Mobility, LLC (“Motorola”) and Metropolitan Life Insurance Company

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(“MetLife”) (Plaintiff, Motorola, and MetLife are referred to as the “Parties”), hereby jointly

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stipulate to an eighth extension of time for Motorola and MetLife to respond to Plaintiff’s

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Complaint. Pursuant to the Parties’ Agreement, the deadline for Motorola and MetLife to file their

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respective responses to Plaintiff’s Complaint will be continued from March 7, 2016 to April 4,

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2016. In support of this Stipulation, the Parties agree and stipulate as follows:

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1.

On June 18, 2015, Plaintiff initiated the present action against Motorola and

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MetLife in the United States District Court for the Northern District of California. (See ECF, Doc.

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No. 1.)

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2.

3.

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Motorola was served with the Summons and Complaint in this action on July 21,

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The Parties submitted stipulations extending the deadline for MetLife to respond to

2015.

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MetLife was served with the Summons and Complaint in this action on June 26,

2015.

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the Complaint to facilitate on-going settlement discussions (See ECF Doc. Nos. 11, 14, 20, 25, 29,

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37, 39, 42.) Where required, the Court granted each of these stipulations. (See ECF Doc. Nos. 22,

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28, 31, 38, 40, 43.)

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5.

The Parties submitted stipulations extending the deadline for Motorola to respond to

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the Complaint to facilitate on-going settlement discussions (See ECF Doc. Nos. 13, 21, 24, 30, 37,

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39, 42.) Where required, the Court granted each of these stipulations. (See ECF Doc. Nos. 23, 27,

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32, 38, 40, 43.)

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6.

Since the last request, the Parties have been engaged in conversations regarding

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JOINT STIPULATION TO CONTINUE DEADLINE FOR DEFENDANTS TO RESPOND TO
PLAINTIFF’S COMPLAINT

{03561257.1}

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settlement and execution of a settlement agreement.
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On March 7, 2016, the Parties agreed to a further twenty-eight (28) day extension of

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time for Motorola and MetLife to respond to Plaintiff’s Complaint. Accordingly, Motorola and

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MetLife’s respective responses to the Complaint are now due on or before April 4, 2016.

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8.

The Parties are optimistic that a resolution can be reached in this matter and the

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additional time will afford the Parties the opportunity to continue their settlement opportunities

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without incurring additional costs of litigation.

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9.

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Court order.

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This Stipulation will not alter the date of any event or any deadline already fixed by

We hereby attest that we have on file all holographic signatures corresponding to
any signatures indicated by a conformed signature (/s/) within this e-filed document.

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Date: March 7, 2016

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MAYNARD, COOPER, & GALE, LLP
By: /s/ Linda B. Oliver
Linda B. Oliver
Attorneys for Defendant
METROPOLITAN LIFE INSURANCE COMPANY

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Date: March 7, 2016

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KANTOR & KANTOR, LLP
By: /s/ Glenn Kantor
Glenn Kantor
Attorneys for Plaintiff
NIA MUJADADI-TURAN

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Date: March 7, 2016

LITTLER MENDELSON, P.C.
By: /s/ Benjamin A. Emmert
Benjamin A. Emmert
Attorneys for Defendant
MOTOROLA MOBILITY, LLC

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JOINT STIPULATION TO CONTINUE DEADLINE FOR DEFENDANTS TO RESPOND TO
PLAINTIFF’S COMPLAINT

{03561257.1}

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CERTIFICATE OF SERVICE
I am employed in the County of San Francisco State of California. I am over the age of
eighteen years and not a party to this action. My business address is 600 Montgomery Street, Suite
2600, San Francisco, CA 94111. On March 7, 2016, I served a copy of the following documents:
JOINT STIPULATION TO CONTINUE DEADLINE FOR DEFENDANTS TO RESPOND
TO PLAINTIFF’S COMPLAINT

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[x]

CM/ECF ELECTRONIC SERVICE: The following are registered CM/ECF users with the
Court, and have consented to service through the Court’s automatic transmission of a notice
of electronic filing.

Glenn Kantor (SBN 122643)
[e-mail]
Beth A. Davis (SBN 277560)
[e-mail]
Andrew Kantor (SBN 303093)
[e-mail]
KANTOR & KANTOR, LLP
19839 Nordhoff Street
Northridge, CA 91324
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff NIA MUJADADI-TURAN

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Benjamin A. Emmert (SBN 212157)
[e-mail]
LITTLER MENDELSON
50 West San Fernando Street, 15th Floor
San Jose, CA 95113-2431
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant MOTOROLA MOBILITY, LLC

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I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct to the best of my knowledge.
Executed on March 7, 2016, at San Francisco, California.

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_______________________________
Mila Dunn

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JOINT STIPULATION TO CONTINUE DEADLINE FOR DEFENDANTS TO RESPOND TO
PLAINTIFF’S COMPLAINT