Filed: Jan. 08, 2019
Latest Update: Jan. 08, 2019
Summary: STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANT NORTHSTAR LOCATION SERVICES, LLC TO FILE ITS OPPOSITION TO PLAINTIFF'S MOTION FOR PARTIAL SUMMARY JUDGMENT [L.R. IA 6-1(b)] GLORIA M. NAVARRO , Chief District Judge . TO THIS HONORABLE COURT : Defendant Northstar Location Services, LLC ("Northstar"), by and through its undersigned counsel of record, Craig J. Mariam of the law firm of Gordon Rees Scully Mansukhani, LLP, and Plaintiff Nicole Diane LaCaria, by and through her undersig
Summary: STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANT NORTHSTAR LOCATION SERVICES, LLC TO FILE ITS OPPOSITION TO PLAINTIFF'S MOTION FOR PARTIAL SUMMARY JUDGMENT [L.R. IA 6-1(b)] GLORIA M. NAVARRO , Chief District Judge . TO THIS HONORABLE COURT : Defendant Northstar Location Services, LLC ("Northstar"), by and through its undersigned counsel of record, Craig J. Mariam of the law firm of Gordon Rees Scully Mansukhani, LLP, and Plaintiff Nicole Diane LaCaria, by and through her undersign..
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STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANT NORTHSTAR LOCATION SERVICES, LLC TO FILE ITS OPPOSITION TO PLAINTIFF'S MOTION FOR PARTIAL SUMMARY JUDGMENT
[L.R. IA 6-1(b)]
GLORIA M. NAVARRO, Chief District Judge.
TO THIS HONORABLE COURT:
Defendant Northstar Location Services, LLC ("Northstar"), by and through its undersigned counsel of record, Craig J. Mariam of the law firm of Gordon Rees Scully Mansukhani, LLP, and Plaintiff Nicole Diane LaCaria, by and through her undersigned counsel of record, Keren Gesund of the law firm of Gesund & Pailet, LLC, hereby stipulate and agree to extend the time for Northstar to file its Opposition to Plaintiff's Partial Motion for Summary Judgment (ECF No. 55), filed on December 21, 2018, from the current deadline of January 11, 2019 to January 25, 2019. The reason for the requested extension is that Plaintiff's Motion for Partial Summary Judgment was filed on the eve of a holiday week and without advanced notice. See Declaration of Craig J. Mariam in Support of Joint Stipulation for Extension of Time for Northstar to File Its Opposition to Plaintiff's Motion for Summary Judgment ("Mariam Decl."), ¶ 3. As such, due to holiday travel and family commitments, defense counsel needs additional time to prepare the Opposition and obtain the necessary client declarations from Northstar's corporate representatives, who likewise have travel and family commitments during late December 2018 and early January 2019. Id., ¶ 4. A brief 14-day extension is therefore necessary in order to avoid substantial prejudice resulting from having to prepare the Opposition and to obtain the requisite client declarations on short notice during a holiday week. Id., ¶ 5.
This is the first stipulation for extension of time for Northstar to file its Opposition to Plaintiff's Motion for Summary Judgment.
IT IS SO STIPULATED.
ORDER
Pursuant to the foregoing Stipulation, Defendant Northstar Location Services, LLC's time to respond to Plaintiff's Motion for Partial Summary Judgment (ECF No. 55) is extended to January 25, 2019.
IT IS SO ORDERED.
