Filed: Dec. 18, 2015
Latest Update: Dec. 18, 2015
Summary: STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT (FIRST REQUEST) [ [Proposed] Order lodged concurrently herewith ] CAM FERENBACH , Magistrate Judge . Plaintiff Robert J. Howard ("Plaintiff"), by and through his counsel of record, Michael Kind (who appeared in the state-court action before it was removed to this Court and will make an appearance in this Court shortly) and Defendant Capital One Bank (USA), N.A., erroneously named as "Capital One" ("Capital One"), by and through its counsel
Summary: STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT (FIRST REQUEST) [ [Proposed] Order lodged concurrently herewith ] CAM FERENBACH , Magistrate Judge . Plaintiff Robert J. Howard ("Plaintiff"), by and through his counsel of record, Michael Kind (who appeared in the state-court action before it was removed to this Court and will make an appearance in this Court shortly) and Defendant Capital One Bank (USA), N.A., erroneously named as "Capital One" ("Capital One"), by and through its counsel ..
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STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT (FIRST REQUEST)
[[Proposed] Order lodged concurrently herewith]
CAM FERENBACH, Magistrate Judge.
Plaintiff Robert J. Howard ("Plaintiff"), by and through his counsel of record, Michael Kind (who appeared in the state-court action before it was removed to this Court and will make an appearance in this Court shortly) and Defendant Capital One Bank (USA), N.A., erroneously named as "Capital One" ("Capital One"), by and through its counsel of record, Brandon C. Fernald, hereby submit this stipulation to extend Capital One's time to file a responsive pleading to Plaintiff's Complaint by thirty (30) days, as follows:
WHEREAS:
1. Plaintiff filed the Complaint in this matter on August 5, 2015, and effectuated service of his Summons and Complaint on Capital One on November 19, 2015;
2. The Parties agree that a brief extension of time for Capital One to file its responsive pleading to the Complaint would benefit both Parties because it will allow them to gather additional facts and information while continuing to devote their resources to exploring the potential for early resolution of this matter before incurring further fees and costs;
3. Capital One and Plaintiff have agreed to extend Capital One's current deadline to respond to Plaintiff's Complaint by thirty (30) days to January 15, 2016;
NOW, THEREFORE, IT IS HEREBY STIPULATED THAT:
CAPITAL ONE will file its responsive pleading to Plaintiff's Complaint on or before January 15, 2016.
IT IS SO STIPULATED.
[PROPOSED] ORDER EXTENDING TIME TO RESPOND TO COMPLAINT
[Stipulation filed concurrently herewith]
ORDER
The Court has reviewed the stipulation filed by Plaintiff Robert J. Howard and Defendant Capital One Bank (USA), N.A. ("Capital One"), to extend Capital One's time to file a responsive pleading by thirty (30) days. The Stipulation is incorporated herein by reference. Good cause appearing thereon, the Court hereby orders as follows:
Capital one's time to file a responsive pleading to complaint is hereby extended. Capital one shall file its responsive pleading to the complaint on or before January 15, 2016.
IT IS SO ORDERED.
