Reynaldo Llamas v. Experian Information Solutions, Inc. et al

Filing 21

ORDER GRANTING 20 Stipulation filed by JPMorgan Chase Bank, National Association. Response due 6/28/2016. Signed by Judge Edward J. Davila on 6/16/2016. (ecg, COURT STAFF) (Filed on 6/16/2016)

Case 5:16-cv-02164-EJD Document 20 Filed 06/14/16 Page 1 of 5

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STROOCK & STROOCK & LAVAN LLP
JULIA B. STRICKLAND (State Bar No. 083013)
STEPHEN J. NEWMAN (State Bar No. 181570)
JULIETA STEPANYAN (State Bar No. 280691)
2029 Century Park East
Los Angeles, CA 90067-3086
Telephone: [phone]
Facsimile: 310-556-5959
Email:
[e-mail]
Attorneys for Defendant
CHASE BANK USA, N.A., erroneously sued as
JPMORGAN CHASE BANK

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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REYNALDO LLAMAS,

)
)
Plaintiff,
)
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vs.
)
)
EXPERIAN INFORMATION SOLUTIONS, )
INC.; EQUIFAX, INC.; JPMORGAN CHASE
)
BANK; TD BANK USA, NATIONAL
)
ASSOCIATION and DOES 1 through 100
)
inclusive,
)
)
Defendants.
)

Case No. 5:16-cv-02164-EJD
[Assigned to the Hon. Howard R. Lloyd]
STIPULATION TO FURTHER
CONTINUE DEADLINE FOR
DEFENDANT CHASE BANK USA, N.A.
TO RESPOND TO COMPLAINT FROM
JUNE 14, 2016, TO JUNE 28, 2016,
PURSUANT TO LOCAL RULE 6-1

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LA 51995340

STIPULATION TO FURTHER CONTINUE
DEADLINE TO RESPOND TO COMPLAINT
Case No. 5:16-cv-02164-EJD

Case 5:16-cv-02164-EJD Document 20 Filed 06/14/16 Page 2 of 5

Plaintiff Reynaldo Llamas (“Plaintiff”) and Defendant Chase Bank USA, N.A., erroneously

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sued as JPMorgan Chase Bank (“Chase”), through their undersigned counsel, hereby stipulate as

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follows:

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WHEREAS, Plaintiff filed the Complaint in this action on April 22, 2016 (Dkt. No.1);

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WHEREAS, the current deadline for Chase to respond to the Complaint is June 14, 2016;

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WHEREAS, pursuant to Local Rule 6-1 the parties may stipulate in writing, without a
Court order, to extend the time within which to answer or otherwise respond to the Complaint,

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provided the change will not alter the date of any event or any deadline already fixed by Court

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order;

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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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WHEREAS, the parties agree to further continue the deadline for Chase to file and serve a

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response to the Complaint by two (2) weeks, to and including June 28, 2016, to allow Chase

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additional time to investigate the allegations in the Complaint;

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WHEREAS, an additional two-week extension of time for Chase to respond to the
Complaint will not alter the date of any event or any deadline already fixed by Court order;
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, between Plaintiff,

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by Plaintiff’s undersigned counsel, and Chase, by its undersigned counsel, that the deadline for

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Chase to respond to the Complaint shall be further continued from June 14, 2016 to June 28, 2016.

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Dated: June 14, 2016

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STROOCK & STROOCK & LAVAN LLP
JULIA B. STRICKLAND
STEPHEN J. NEWMAN
JULIETA STEPANYAN
By:

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/s/ Julieta Stepanyan
Julieta Stepanyan

Attorneys for Defendant
CHASE BANK USA, N.A., erroneously sued
as JPMorgan Chase Bank

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-1-

LA 51995340

STIPULATION TO FURTHER CONTINUE
DEADLINE TO RESPOND TO COMPLAINT
Case No. 5:16-cv-02164-EJD

Case 5:16-cv-02164-EJD Document 20 Filed 06/14/16 Page 3 of 5

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Dated: June 14, 2016

SAGARIA LAW- A PROFESSIONAL
CORPORATION

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By:

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ELLIOT W. GALE
[e-mail]
SAGARIA LAW- A PROFESSIONAL
CORPORATION
2033 Gateway Place, 5th Floor
San Jose, CA 95110
Telephone: [phone]
Facsimile: [phone]

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Attorney for Plaintiff
REYNALDO LLAMAS

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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

/s/ Elliot Gale
Elliot W. Gale

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LA 51995340

STIPULATION TO FURTHER CONTINUE
DEADLINE TO RESPOND TO COMPLAINT
Case No. 5:16-cv-02164-EJD

Case 5:16-cv-02164-EJD Document 20 Filed 06/14/16 Page 4 of 5

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ECF Signature Certification

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Pursuant to Civil L.R. 5-1(i)(3), I hereby certify that the content of this document is

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acceptable to Elliot Gale, counsel for Plaintiff, and that I have obtained Mr. Gale’s authorization to

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affix his electronic signature to this document.

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Dated: June 14, 2016

/s/ Julieta Stepanyan
Julieta Stepanyan

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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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LA 51995340

STIPULATION TO FURTHER CONTINUE
DEADLINE TO RESPOND TO COMPLAINT
Case No. 5:16-cv-02164-EJD

Case 5:16-cv-02164-EJD Document 20 Filed 06/14/16 Page 5 of 5

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CERTIFICATE OF SERVICE

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I hereby certify that, on June 14, 2016, copies of the foregoing STIPULATION TO

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FURTHER CONTINUE DEADLINE FOR DEFENDANT CHASE BANK USA, N.A. TO

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RESPOND TO COMPLAINT FROM JUNE 14, 2016, TO JUNE 28, 2016, PURSUANT TO

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LOCAL RULE 6-1 were filed electronically and served by U.S. Mail on anyone unable to accept

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electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the court’s

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electronic filing system or by facsimile to anyone unable to accept electronic filing as indicated on

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the Notice of Electronic Filing. Parties may access this filing through the court’s EM/ECF System.

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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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By:

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/s/ Julieta Stepanyan
Julieta Stepanyan

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LA 51995340

CERTIFICATE OF SERVICE
Case No. 5:16-cv-02164-EJD