Mark Conklin v. Equifax Inc. et al

Filing 16

ORDER GRANTING 15 Stipulation for Extension of Time to File Response filed by Toyota Motor Credit Corporation. Response due 1/15/2016. Signed by Judge Edward J. Davila on 1/15/2016. (ecg, COURT STAFF) (Filed on 1/15/2016)

Case 5:15-cv-05114-EJD Document 15 Filed 01/12/16 Page 1 of 2

S

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w a rd J
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. D av i l a

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Attorneys for Defendant
TOYOTA MOTOR CREDIT
7 CORPORATION
6

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5

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3 355 South Grand Avenue, Suite 2900
Los Angeles, CA 90071-1514
4 Telephone: [phone]
Facsimile: [phone]

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Cristyn N. Chadwick (SBN 280705)

2 REED SMITH LLP

RT
U
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1 Abraham J. Colman (SBN 146933)

ISTRIC
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8
9

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E R DATED: 1/15/2016 C
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F
D IS T IC T O
R
UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA – SAN JOSE DIVISION

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10
11 MARK CONKLIN,
12

Plaintiff,

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vs.
14 EQUIFAX, INC.; TOYOTA MOTOR
15

CREDIT CORPORATION; and DOES 1
through 100 inclusive,

16

Defendants.

Case No. 5:15-CV-05114-EJD-NMC
STIPULATION TO EXTEND TIME
FOR TOYOTA MOTOR CREDIT
CORPORATION TO RESPOND TO
COMPLAINT
[L.R. 6-1]
Compl. Filed: November 9, 2015
Trial Date:
None set

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The Hon. Edward J. Davila

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Pursuant to Local Rule 6-1, Plaintiff Mark Conklin (“Plaintiff”) and Defendant

21 Toyota Motor Credit Corporation (“TMCC”) by and through their respective counsel
22 of record, hereby stipulate as follows:
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WHEREAS, Plaintiff filed the Complaint in this action on November 9, 2015;

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WHEREAS, on December 8, 2015, TMCC was served with the Complaint;

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WHEREAS, pursuant to Federal Rule of Civil Procedure 12(a)(1)(A), TMCC’s

26 final day to answer or otherwise respond to Plaintiff’s Complaint was December 29,
27 2015;
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–1–
STIPULATION TO EXTEND TIME FOR DEFENDANT TOYOTA MOTOR CREDIT
CORPORATION TO RESPOND TO COMPLAINT

Case 5:15-cv-05114-EJD Document 15 Filed 01/12/16 Page 2 of 2

WHEREAS, TMCC’s counsel was recently retained in this matter and, due to

1

2 an administrative error, the undersigned did not receive notice of the lawsuit or a copy
3 Complaint until after the time to respond had passed;

WHEREAS, TMCC requires additional time to review the allegations before

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5 responding to the Complaint;

WHEREAS, Plaintiff has agreed to grant TMCC an extension of time, until

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7 January 15, 2016, to respond to the Complaint,

WHEREAS, an Initial Case Management Conference has been set for April 21,

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9 2016 at 10:00 a.m. in Courtroom 4, and a Joint Case Management Statement is due for

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 filing by April 14, 2016.

WHEREAS, extending TMCC’s time to respond to the complaint until January

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12 15, 2016 will not alter the date of any deadline fixed by Court order;

NOW, THEREFORE, the Parties hereby stipulate that TMCC shall have up to

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14 and including January 15, 2016, to respond to Plaintiff’s Complaint.
15 IT IS SO STIPULATED.
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17

DATED: January 12, 2016

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SAGARIA LAW. P.C.
By

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DATED: January 12, 2016

/s/ Elliot W. Gale
Elliot W. Gale
Attorneys for Plaintiff
Mark Conklin

REED SMITH LLP

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By

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/s/ Cristyn N. Chadwick1
Cristyn N. Chadwick
Attorneys for Defendant
Toyota Motor Credit Corporation

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1

Pursuant to Northern District Local Rule 5-1(i)(3), filing counsel attests that all other

27 signatories listed and on whose behalf this filing is submitted concur in the filing’s
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content and have authorized the filing.

–2–
STIPULATION TO EXTEND TIME FOR DEFENDANT TOYOTA MOTOR CREDIT
CORPORATION TO RESPOND TO COMPLAINT