Opinion
C21-1074-JCC-SKV
12-08-2021
JOSE MEDINA CAMACHO, on behalf of himself and all others similarly situated, Plaintiff, v. PEOPLECONNECT, INC., a Delaware corporation; INTELIUS LLC, a Delaware limited liability company; and THE CONTROL GROUP MEDIA COMPANY, LLC, Defendants.
GORDON TILDEN THOMAS & CORDELL LLP Attorneys for Defendants PeopleConnect, Inc., Intelius LLC and The Control Group Media Company, LLC By: s/ Michael Rosenberger Michael Rosenberger, WSBA #17730 Mark Wilner, WSBA #31550 Samantha K. Pitsch, WSBA #54190 TOUSLEY BRAIN STEPHENS Attorneys for Plaintiff Jose Medina Camacho Kim D. Stephens (WSBA #11984) Cecily Jordan (WSBA #50061) Ari J. Scharg (pro hac vice) Benjamin H. Richman (pro hac vice) Benjamin S. Thomassen (pro hac vice) EDELSON P.C. Kevin Abramowicz (pro hac vice) Kevin W Tucker (pro hac vice) EAST END TRIAL GROUP LLC
NOTE ON MOTION CALENDAR: December 7, 2021
GORDON TILDEN THOMAS & CORDELL LLP Attorneys for Defendants PeopleConnect, Inc., Intelius LLC and The Control Group Media Company, LLC By: s/ Michael Rosenberger Michael Rosenberger, WSBA #17730 Mark Wilner, WSBA #31550 Samantha K. Pitsch, WSBA #54190
TOUSLEY BRAIN STEPHENS Attorneys for Plaintiff Jose Medina Camacho Kim D. Stephens (WSBA #11984) Cecily Jordan (WSBA #50061) Ari J. Scharg (pro hac vice) Benjamin H. Richman (pro hac vice) Benjamin S. Thomassen (pro hac vice) EDELSON P.C. Kevin Abramowicz (pro hac vice) Kevin W Tucker (pro hac vice) EAST END TRIAL GROUP LLC
STIPULATED MOTION AND [PROPOSED] ORDER TO EXTEND DEADLINES AND TO STAY DISCOVERY
S. KATE VAUGHAN United States Magistrate Judge
The Parties respectfully move for an agreed briefing schedule for Defendants' motion to dismiss and to stay discovery pending resolution of Defendants' motion to dismiss. In support of this Motion, the Parties state as follows:
1. Plaintiff filed a class action complaint against PeopleConnect, Inc. and Intelius LLC on August 11, 2021 (Dkt. No. 1).
2. Defendants PeopleConnect, Inc. and Intelius LLC waived service, resulting in a date to answer or otherwise plead of November 29, 2021 (Dkt. No. 17).
3. On October 28, 2021, Plaintiff filed a First Amended Class Action Complaint (“Complaint”), adding The Control Group Media Company, LLC as a Defendant (Dkt. No. 19).
4. On October 28, 2021, counsel for Defendants agreed to waive service for The Control Group Media Company, LLC. Given that agreement, The Control Group Media Company, LLC's date to answer or otherwise respond to Plaintiff's Complaint is December 27, 2021.
5. To reconcile the competing responsive dates, and in the interests of efficiency and judicial economy, the Parties agreed that the deadline for all three Defendants to answer or otherwise respond to Plaintiff's Complaint should be on the same date, up to and including December 27, 2021. On November 4, 2021, this Court entered an order extending the deadline for all Defendants (PeopleConnect, Inc., Intelius LLC, and The Control Group Media Company, LLC) to respond to Plaintiff's Complaint up to and including December 27, 2021. (Dkt. No. 22.)
6. Because of competing prior obligations in a number of matters for both Parties, the Parties have agreed to extend Defendants' deadline to file its motion to dismiss Plaintiff's Amended Complaint up to and including January 14, 2022.
7. The Parties agree that Plaintiff will have until February 11, 2022, to file a response to Defendants' motion to dismiss.
8. The Parties agree that Defendants will have until February 18, 2022, to file a reply in support of their motion to dismiss.
9. The Parties agree to stay discovery pending the resolution of Defendants' motion to dismiss.
WHEREFORE, for the reasons stated herein, the Parties respectfully request that this Court grant this Motion and enter an Order extending the deadline for all Defendants (PeopleConnect, Inc., Intelius LLC, and The Control Group Media Company, LLC) to respond to Plaintiff's Complaint up to and including January 14, 2022, for Plaintiff to respond up to and including February 11, 2022, and for Defendants to file their reply in support of their motion to dismiss up to and including February 18, 2022, and to stay discovery pending resolution of Defendants' motion to dismiss.
IT IS SO ORDERED.