Gragg v. Orange Cab Company et al

Filing 23

STIPULATION AND ORDER (1) GRANTING PLAINTIFF LEAVE TO FILE FIRST AMENDED COMPLAINT AND (2) EXTENDING DEADLINE FOR ORANGE CAB AND RIDECHARGE TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S FIRST AMENDED COMPLAINT by Judge Robert S. Lasnik; Pursuant to the parties' 22 Stipulation, plaintiff is granted leave to file First Amended Complaint. Defendants Orange Cab Company, Inc. and Ridecharge, Inc. are granted until July 20, 2012, to answer or otherwise respond to Plaintiffs First Amended Complaint. (TF)

THE HONORABLE ROBERT S. LASNIK

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

9 TORREY GRAGG, on his own behalf and on
behalf of similarly situated persons,
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Plaintiff,
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v.
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ORANGE CAB COMPANY, INC., a
13 Washington corporation; and RIDECHARGE,
INC., a Delaware corporation d/b/a TAXI
14 MAGIC,
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Defendants.

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Case No. 2:12-cv-00576-RSL
STIPULATION AND ORDER
(1) GRANTING PLAINTIFF
LEAVE TO FILE FIRST
AMENDED COMPLAINT AND
(2) EXTENDING DEADLINE FOR
ORANGE CAB AND
RIDECHARGE TO ANSWER OR
OTHERWISE RESPOND TO
PLAINTIFF’S FIRST AMENDED
COMPLAINT

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STIPULATION
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Plaintiff requests leave to file a First Amended Complaint to plead claims under the
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Telephone Consumer Protection Act, 47 U.S.C. § 227. Pursuant to Fed. R. Civ. P. 15(a)(2),
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Defendants have agreed herein to provide written consent for Plaintiff to file his First Amended
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Complaint attached at Exhibit A. In conjunction with the filing of Plaintiff’s First Amended
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Complaint, the parties, by and through their attorneys of record, respectfully request that the
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Court enter the proposed Order set forth below, which extends the deadline for Defendants
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Orange Cab Company, Inc. (“Orange Cab”) and Ridecharge, Inc. (“Ridecharge”) to answer or
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otherwise respond to Plaintiff’s First Amended Complaint, until July 20, 2012.
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STIPULATION REGARDING AMENDED COMPLAINT
AND RESPONSE DEADLINE
(No. 2:12-cv-00576-RSL) — 1

HEYRICH KALISH MCGUIGAN PLLC
1325 Fourth Avenue, Suite 540
Seattle, Washington 98101
[phone]

1 Stipulated and respectfully submitted this 29th day of June, 2012, by:
2 DAVIS WRIGHT TREMAINE LLP
Attorneys for Defendants
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4 By:
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s/ Ryan C. Gist
Kenneth E. Payson, WSBA #26369
Ryan C. Gist, WSBA #41816
1201 Third Avenue, Suite 2200
Seattle, Washington 98101-3045
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
[e-mail]

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HEYRICH KALISH MCGUIGAN PLLC
10 Counsel for Plaintiff
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s/ Donald W. Heyrich
Donald W. Heyrich, WSBA #23091
1325 Fourth Ave, Suite 540
Seattle, Washington 98101
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
KIRBY LAW GROUP
Albert H. Kirby, WSBA #23091
93 S. Jackson St. #63230
Seattle, Washington 98104
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]

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STIPULATION REGARDING AMENDED COMPLAINT
AND RESPONSE DEADLINE
(No. 2:12-cv-00576-RSL) — 2

HEYRICH KALISH MCGUIGAN PLLC
1325 Fourth Avenue, Suite 540
Seattle, Washington 98101
[phone]

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ORDER
Having reviewed the foregoing stipulation of the parties, plaintiff is granted leave to file

3 Plaintiff’s First Amended Complaint. Defendants Orange Cab Company, Inc. (“Orange Cab”)
4 and Ridecharge, Inc. (“Ridecharge”) are granted until July 20, 2012, to answer or otherwise
5 respond to Plaintiff’s First Amended Complaint.
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IT IS SO ORDERED.

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DATED this 2nd day of July, 2012.

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A
Robert S. Lasnik

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United States District Judge 

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14 Presented by:
15 HEYRICH KALISH MCGUIGAN PLLC
Counsel for Plaintiff
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By:
s/ Donald W. Heyrich
Donald W. Heyrich, WSBA #23091
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1325 Fourth Ave, Suite 540
Seattle, Washington 98101
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Telephone: [phone]
Fax: [phone]
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E-mail: [e-mail]
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STIPULATION REGARDING AMENDED COMPLAINT
AND RESPONSE DEADLINE
(No. 2:12-cv-00576-RSL) — 3

HEYRICH KALISH MCGUIGAN PLLC
1325 Fourth Avenue, Suite 540
Seattle, Washington 98101
[phone]