Filed: Dec. 05, 2014
Latest Update: Dec. 05, 2014
Summary: STIPULATION TO EXTEND TIME TO RESPOND TO SECOND AMENDED COMPLAINT OR, IN THE ALTERNATIVE, TO THIRD AMENDED COMPLAINT AND ORDER VINCE CHHABRIA, District Judge. Pursuant to Civil Local Rule 6-1(a), Plaintiff DAVID MCDONALD, by and through his attorney of record, Benjamin D. Rothstein of the Keker & Van Nest LLP Law firm, and Defendant ANTHONY SOUZA, by and through his attorney, Deputy County Counsel Nima E. Sohi of the Contra Costa County Counsel's Office, hereby stipulate as follows: WHEREAS P
Summary: STIPULATION TO EXTEND TIME TO RESPOND TO SECOND AMENDED COMPLAINT OR, IN THE ALTERNATIVE, TO THIRD AMENDED COMPLAINT AND ORDER VINCE CHHABRIA, District Judge. Pursuant to Civil Local Rule 6-1(a), Plaintiff DAVID MCDONALD, by and through his attorney of record, Benjamin D. Rothstein of the Keker & Van Nest LLP Law firm, and Defendant ANTHONY SOUZA, by and through his attorney, Deputy County Counsel Nima E. Sohi of the Contra Costa County Counsel's Office, hereby stipulate as follows: WHEREAS Pl..
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STIPULATION TO EXTEND TIME TO RESPOND TO SECOND AMENDED COMPLAINT OR, IN THE ALTERNATIVE, TO THIRD AMENDED COMPLAINT AND ORDER
VINCE CHHABRIA, District Judge.
Pursuant to Civil Local Rule 6-1(a), Plaintiff DAVID MCDONALD, by and through his attorney of record, Benjamin D. Rothstein of the Keker & Van Nest LLP Law firm, and Defendant ANTHONY SOUZA, by and through his attorney, Deputy County Counsel Nima E. Sohi of the Contra Costa County Counsel's Office, hereby stipulate as follows:
WHEREAS Plaintiff's Second Amended Complaint was filed on August 15, 2014 in the Superior Court of California, County of Marin, and removed to this Court on September 15, 2014;
WHEREAS on or around November 14, 2014, Defendant ANTHONY SOUZA was personally served with Plaintiff's Second Amended Complaint;
WHEREAS the response to the Second Amended Complaint, by Defendant ANTHONY SOUZA, is currently due on or around December 5, 2014;
WHEREAS Plaintiff intends to seek leave from the Court to file an amended pleading on or before December 5, 2014;
THEREFORE, pursuant to Civil Local Rule 6-1(a), the parties have stipulated and agreed as follows:
If the court denies Plaintiff's forthcoming motion for leave to file an amended pleading, the deadline for Defendant ANTHONY SOUZA to answer or otherwise respond to the Second Amended Complaint shall be 30 days following the date of entry of the order denying Plaintiff's motion;
If the court grants Plaintiff's forthcoming motion for leave to file an amended pleading, the deadline for Defendant ANTHONY SOUZA to answer or otherwise respond to the amended pleading shall be 30 days following the date of service of the amended pleading;
The undersigned counsel for Defendant Anthony Souza agrees to accept service of the Third Amended Complaint, if any, via e-mail; and
Pursuant to Civil Local Rule 6-1(a), the parties attest that the extension of time to answer or otherwise respond to the Second Amended Complaint or Third Amended Complaint, if any, will not alter the date of any event or any deadline already fixed by Court order.
IT IS SO STIPULATED.
