Opinion
2:21-cv-01222-MJP
12-06-2021
JOHN BOSHEARS, on behalf of himself and all others similarly situated, Plaintiff, v. PEOPLECONNECT, INC., a Delaware corporation, Defendant.
GORDON TILDEN THOMAS & CORDELL LLP Attorneys for Defendant PeopleConnect, Inc. TURKE & STRAUSS LLP Attorneys for Plaintiff John Boshears Michael Rosenberger, Mark Wilner, Samantha K. Pitsch, Raina C. Borrelli (pro hac vice) Samuel J. Strauss, Brent Caslin, Debbie L. Berman (pro hac vice) Wade A. Thomson (pro hac vice)
GORDON TILDEN THOMAS & CORDELL LLP Attorneys for Defendant PeopleConnect, Inc. TURKE & STRAUSS LLP Attorneys for Plaintiff John Boshears Michael Rosenberger, Mark Wilner, Samantha K. Pitsch, Raina C. Borrelli (pro hac vice) Samuel J. Strauss, Brent Caslin, Debbie L. Berman (pro hac vice) Wade A. Thomson (pro hac vice)
STIPULATED MOTION AND ORDER FOR EXTENSION OF DEADLINES
NOTE ON MOTION CALENDAR: December 6, 2021
Marsha J. Pechman United States Senior District Judge
The Parties respectfully move for an agreed briefing schedule for Defendant's motion to dismiss and motion to stay. In support of this motion, the Parties state as follows:
1. On October 29, 2021, Plaintiff's counsel filed an Amended Complaint substituting John Boshears as the named plaintiff in place of Mr. Fry. (Dkt. No. 17.)
2. On November 2, 2021, this Court entered an Order extending Defendant's deadline to answer or otherwise respond to Plaintiff's Amended Complaint to December 13, 2021. (Dkt. No. 19.) 1
3. Because of competing prior obligations in a No. of matters for both Parties, the Parties have agreed to extend Defendant's deadline to file its motion to dismiss Plaintiff's Amended Complaint to December 20, 2021.
4. Separately, Defendant also will be filing a motion to stay discovery on December 20, 2021.
5. The Parties agree that Plaintiff will have until January 14, 2022, to respond to Defendant's motion to dismiss and respond to Defendant's motion to stay discovery.
6. The Parties also agree that Defendant will have until January 21, 2022, to file its reply briefs in support of its motion to dismiss and to its motion to stay discovery.
WHEREFORE, for the reasons stated herein, the parties respectfully request that the Court grant this motion and enter an Order extending the deadline for Defendant to respond to Plaintiff's Amended Complaint up to and including December 20, 2021, Plaintiff to file an opposition to both Defendant's motion to dismiss and motion to stay discovery up to and including January 14, 2022, and for Defendant to file its reply briefs in support of its motion to dismiss and its motion to stay discovery, up to and including January 21, 2022.
[SIGNATURES ON FOLLOWING PAGE] 2
ORDER
Although the Parties provide a threadbare justification for the requested extension, the Court GRANTS the brief extension of time. No. further extensions of these deadlines shall be considered absent extraord inary circumstances. 3