Filed: Sep. 22, 2016
Latest Update: Sep. 22, 2016
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND PLAINTIFF'S TIME TO OPPOSE DEFENDANT'S MOTION TO DISMISS COMPLAINT EDWARD M. CHEN , District Judge . Pursuant to Local Rule 6-2, Plaintiff Gloria A. Mestayer ("Plaintiff"), by and through her counsel of record, Clark Ovruchesky of the Law Office of Clark Ovruchesky, and Defendant Capital One Bank (USA), N.A. ("Capital One"), by and through its counsel of record, Amy Borlund of Doll Amir & Eley LLP, hereby submit this Stipulation To Extend Pla
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND PLAINTIFF'S TIME TO OPPOSE DEFENDANT'S MOTION TO DISMISS COMPLAINT EDWARD M. CHEN , District Judge . Pursuant to Local Rule 6-2, Plaintiff Gloria A. Mestayer ("Plaintiff"), by and through her counsel of record, Clark Ovruchesky of the Law Office of Clark Ovruchesky, and Defendant Capital One Bank (USA), N.A. ("Capital One"), by and through its counsel of record, Amy Borlund of Doll Amir & Eley LLP, hereby submit this Stipulation To Extend Plai..
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STIPULATION AND [PROPOSED] ORDER TO EXTEND PLAINTIFF'S TIME TO OPPOSE DEFENDANT'S MOTION TO DISMISS COMPLAINT
EDWARD M. CHEN, District Judge.
Pursuant to Local Rule 6-2, Plaintiff Gloria A. Mestayer ("Plaintiff"), by and through her counsel of record, Clark Ovruchesky of the Law Office of Clark Ovruchesky, and Defendant Capital One Bank (USA), N.A. ("Capital One"), by and through its counsel of record, Amy Borlund of Doll Amir & Eley LLP, hereby submit this Stipulation To Extend Plaintiff's Time To Oppose Capital One's Motion to Dismiss ("MTD") Plaintiff's Third Amended Complaint ("TAC"), as follows:
WHEREAS:
1. Plaintiff filed the TAC on July 20, 2016;
2. Capital One filed a MTD Plaintiff's TAC on September 9, 2016;
3. The MTD hearing is scheduled to occur on October 27, 2016;
4. Plaintiff's current deadline to oppose Capital One's MTD is September 23, 2016;
5. Plaintiff's counsel respectfully requests additional time to oppose Capital One's MTD to address Capital One's "Metro 2" credit reporting arguments.
6. Capital One agreed to extend Plaintiff's deadline to oppose Capital One's MTD by one week—to September 30, 2016.
7. This extension would only additionally alter the date of Capital One's deadline to file a reply to Plaintiff's opposition, but the MTD heading would still be three weeks away from the modified deadline for Capital One to file a reply.
NOW, THEREFORE, IT IS HEREBY STIPULATED THAT:
Plaintiff's deadline to file an opposition to Capital One's MTD is extended from September 23, 2016 to September 30, 2016, and Capital One's deadline to file a reply to Plaintiff's opposition is extended from September 30, 2016 to
SIGNATURE CERTIFICATION
Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative Policies and Procedures Manual, I hereby certify that the content of this document is acceptable to all defense counsels listed above, and that I have obtained their authorizations to affix their electronic signatures to this document.
PURSUANT TO STIPULATION, IT IS SO ORDERED that Plaintiff's deadline to file an opposition to Capital One's MTD is extended from September 23, 2016 to September 30, 2016, and Capital One's deadline to file a reply to Plaintiff's opposition is extended from September 30, 2016 to October 7, 2016.
