Opinion
No.: 3:12-cv-01682-MMC
03-18-2013
JACQUELINE ANDERSON, Plaintiff, v. CHARLES SCHWAB AND COMPANY, INC., and DOES 1 through 100, inclusive, Defendants.
Deborah J. Broyles (SBN 167681) Tiffany Renee Thomas (SBN 239085) REED SMITH LLP Attorneys for Defendant Charles Schwab & Co., Inc. Murlene J. Randle Attorneys for Plaintiff Jacqueline Anderson
Deborah J. Broyles (SBN 167681)
Tiffany Renee Thomas (SBN 239085)
REED SMITH LLP
Attorneys for Defendant
Charles Schwab & Co., Inc.
STIPULATION AND [PROPOSED] ORDER
EXTENDING DEFENDANT CHARLES
SCHWAB & CO., INC.'S TIME TO
RESPOND TO COMPLAINT
Hon. Maxine M. Chesney
Plaintiff Jacqueline Anderson ("Plaintiff") and Defendant Charles Schwab & Co., Inc. ("Defendant"), by and through their undersigned counsel of record, hereby stipulate as follows:
WHEREAS, on January 11, 2013, the parties filed a Stipulation and [Proposed] Order seeking leave for Plaintiff's filing of a Third Amended Complaint [Doc 19];
WHEREAS, on January 15, 2013, this Court granted Plaintiff leave to file a Third Amended Complaint [Doc. 20];
WHEREAS, on January 17, 2013, Plaintiff filed a Third Amended Complaint [Doc. 21];
WHEREAS, the Third Amended Complaint contains 270 separate and distinct paragraphs;
WHEREAS, Defendant intends to file an answer to the Third Amended Complaint;
WHEREAS, the parties stipulated to, and the court granted, an extension of Defendant's time to file its answer to March 1, 2013 [Docs. 22, 24]
WHEREAS, the parties stipulated to, and the court granted, an extension of Defendant's time to file its answer to March 15, 2013 [Docs. 22, 24]
WHEREAS, Defendant will be unable to complete its Answer by March 15, 2013;
WHEREAS, an extension of time will not affect the case management schedule for this action; and
WHEREAS, the instant Stipulation and [Proposed] Order constitutes the parties' third request for a time modification in this action.
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by Plaintiff and Defendant that:
Pursuant to this stipulation, the parties agree to continue Defendant's deadline to file its responsive pleading to the Third Amended Complaint from March 1, 2013 to March 22, 2013.
SO STIPULATED.
REED SMITH, LLP
By: _______________
Deborah J. Broyles
Tiffany Renee Thomas
Attorneys for Defendant Charles Schwab & Co., Inc.
Law Offices of Murlene J. Randle
By: _______________
Murlene J. Randle
Attorneys for Plaintiff Jacqueline Anderson
ORDER
Pursuant to the stipulation of the parties and good cause appearing, IT IS HEREBY ORDERED THAT Defendant Charles Schwab & Co., Inc. must file a responsive pleading to Plaintiff Jacqueline Anderson's Third Amended Complaint no later than March 22, 2013. Given the limited nature of the amendments and defendant's having been aware of said amendments no later than January 17, 2013, however, such extension shall not constitute good cause to amend the Pretrial Preparation Order in any manner.
IT IS SO ORDERED.
_______________
The Honorable Maxine Chesney
United States District Judge