Hennessey v. Americredit Financial Services Inc et al

Filing 65

ORDER re Parties' 64 Stipulated MOTION to Extend Time to Reply to Defendants' Joint Response. The deadline for the Plaintiff to file a Reply to Defendants' Joint Response to Plaintiff's 54 Motion for Relief from Order and Judgement & Request for Indicative Ruling Under Rule 62.1 (A) is extended until and including November 11, 2024. Signed by U.S. District Judge David G Estudillo.(MW)

HONORABLE DAVID. G. ESTUDILLO

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON AT TACOMA
JANICE HENNESSEY,

) Case No. 3:24-cv-05145-DGE
)
Plaintiff,
) STIPULATED MOTION AND ORDER TO
) EXTEND TIME TO REPLY TO
vs.
) DEFENDANTS’ RESPONSE TO MOTION
) FOR RELIEF AND CONTINUE MOTION
AMERICREDIT FINANCIAL SERVICES )
INC. DBA GM FINANCIAL, HOBLIT
) NOTE ON MOTION CALENDAR:
AUTOMOTIVE, INC. DBA HOBLIT
)
CHEVROLET BUICK GMC,
) OCTOBER 22, 2024
)
)
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)
Defendants.
)
)
STIPULATED MOTION
COME NOW, the parties, by and through their counsel of record, and submit the
following stipulated motion and proposed order to extend the time for Plaintiff to file a Reply
to Defendants’ Joint Response to Plaintiff’s Motion for Relief from Order and Judgement &
Request for Indicative Ruling Under Rule 62.1(A) (DKT. #54). This Motion is noted for
October 28, 2024, making the current deadline for the Plaintiff to file a Reply by the same
date of October 28, 2024. The parties stipulate and request the deadline to be extended 14
days to November 11, 2024. The grounds for this motion are as follows:
Due to unexpected health matters and worsened illness/infection, Plaintiff requires an

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STIPULATED MOTION AND ORDER TO
EXTEND TIME TO REPLY TO
DEFENDANTS’ RESPONSE TO MOTION
FOR RELIEF – NOTE ON MOTION
CALENDAR – OCTOBER 15, 2024 - 1

Janice Hennessey, Pro Se Plaintiff
855 Trosper Road SW, #108-157
Tumwater, WA 98512
Tel. [phone]
Email: [e-mail]

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additional 14 days to recover from her worsened medical condition and properly prepare her

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reply. The parties have conferred, Plaintiff provided a medical record, and the Defendants

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have graciously agreed to the stipulated request for the extension. Plaintiff proposes to extend

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her deadline to November 11, 2024, with the motion being noted on the same date. Plaintiff
also agrees to limit her reply brief to 2,100 words, pursuant to LCR 7(e)(4).
Pursuant to Local Civil Rule 7(j), the Court may, for good cause, extend the deadlines for
filings. Plaintiff’s request is based on medical/health issues, which have limited her ability to
meet the original filing deadline. Defendants have agreed to the extension, and no party will
be prejudiced by this short delay.
For the reasons set forth above, Plaintiff respectfully requests that the Court approve this

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stipulated motion and issue an order extending the deadline for Plaintiff’s Reply to November

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11, 2024, and noting the motion for the same date.

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IT IS SO STIPULATED this 22nd day of October, 2024.
By: s/ Janice Hennnessey
JANICE HENNESSEY, Pro Se Litigant
Email: [e-mail]
855 Trosper Road SW, #108-157
Tumwater, WA 98512
Telephone: [phone]
By: s/ Megan M. Coluccio
MEGAN M. COLUCCIO, WSBA #44178
ROBERT L. CHRISTIE, WSBA #44178
Attorneys for Hoblit Automotive, Inc.
2100 Westlake Avenue N. Suite 206
Seattle, WA 98109
Phone: [phone]
Fax: [phone]
STIPULATED MOTION AND ORDER TO
EXTEND TIME TO REPLY TO
DEFENDANTS’ RESPONSE TO MOTION
FOR RELIEF – NOTE ON MOTION
CALENDAR – OCTOBER 15, 2024 - 2

By:

s/ Binah B.Yeung
BINAH B. YEUNG, WSBA #44065
Attorney for Defendant GM Financial
524 2nd Avenue, Ste. 500
Seattle, WA 98104-2323
Phone: [phone]
Email: [e-mail]

Janice Hennessey, Pro Se Plaintiff
855 Trosper Road SW, #108-157
Tumwater, WA 98512
Tel. [phone]
Email: [e-mail]

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Email: [e-mail]
Email: [e-mail]
I certify that this memorandum contains 287
words, in compliance with the Local Rules
Civil Rules.

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ORDER
Based upon the foregoing Stipulation,
IT IS HEREBY ORDERED, ADJUDGED AND DECREED that the deadline for the
Plaintiff to file a Reply to Defendants’ Joint Response to Plaintiff’s Motion for Relief from

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Order and Judgement & Request for Indicative Ruling Under Rule 62.1 (A) is extended until

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and including November 11, 2024.

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DONE IN OPEN COURT this 23rd day of October 2024.

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___a___________________
HONORABLE DAVID G. ESTUDILLO
United States District Court Judge

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Presented By:

By: s/ Janice Hennnessey
JANICE HENNESSEY, Pro Se Litigant
Email: [e-mail]
855 Trosper Road SW, #108-157
Tumwater, WA 98512
Telephone: [phone]
By: s/ Megan M. Coluccio
MEGAN M. COLUCCIO, WSBA #44178
STIPULATED MOTION AND ORDER TO
EXTEND TIME TO REPLY TO
DEFENDANTS’ RESPONSE TO MOTION
FOR RELIEF – NOTE ON MOTION
CALENDAR – OCTOBER 15, 2024 - 3

By:

s/ Binah B.Yeung
BINAH B. YEUNG, WSBA #44065
Attorney for Defendant GM Financial
524 2nd Avenue, Ste. 500
Seattle, WA 98104-2323
Phone: [phone]
Email: [e-mail]

Janice Hennessey, Pro Se Plaintiff
855 Trosper Road SW, #108-157
Tumwater, WA 98512
Tel. [phone]
Email: [e-mail]

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ROBERT L. CHRISTIE, WSBA #44178
Attorneys for Hoblit Automotive, Inc.
2100 Westlake Avenue N. Suite 206
Seattle, WA 98109
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Email: [e-mail]

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STIPULATED MOTION AND ORDER TO
EXTEND TIME TO REPLY TO
DEFENDANTS’ RESPONSE TO MOTION
FOR RELIEF – NOTE ON MOTION
CALENDAR – OCTOBER 15, 2024 - 4

Janice Hennessey, Pro Se Plaintiff
855 Trosper Road SW, #108-157
Tumwater, WA 98512
Tel. [phone]
Email: [e-mail]

CERTIFICATE OF SERVICE

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I, Janice Hennessey, hereby certify that I caused a copy of the foregoing to be served
on the parties listed below, via the Court’s CM/ECF System on October 22, 2024.

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Binah Yeung [e-mail]
Cairncross & Hempelmann, P.S.
524 Second Ave., Ste. 500
Seattle, WA 98104
main: 206-587-0700
fax: [phone]

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Attorney for Defendant AmeriCredit Financial Services dba GM Financial

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Robert Christie [e-mail]
Megan Coluccio [e-mail]
Laura Pfeifer [e-mail]
Baker Sterchi Cowden & Rice LLC
2100 Westlake Ave. N., Ste. 206
Seattle, WA 98109
main: 206-957-9669
fax: [phone]
Attorneys for Defendant Hoblit Automotive, Inc., d/b/a Hoblit Chevrolet Buick GMC
Dated: October 22, 2024

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Janice Hennessey

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By: s/ Janice Hennnessey
JANICE HENNESSEY, Pro Se Litigant
Email: [e-mail]
855 Trosper Road SW, #108-157
Tumwater, WA 98512
Telephone: [phone]

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STIPULATED MOTION AND ORDER TO
EXTEND TIME TO REPLY TO
DEFENDANTS’ RESPONSE TO MOTION
FOR RELIEF – NOTE ON MOTION
CALENDAR – OCTOBER 15, 2024 - 5

Janice Hennessey, Pro Se Plaintiff
855 Trosper Road SW, #108-157
Tumwater, WA 98512
Tel. [phone]
Email: [e-mail]