Opinion
Case No. CV11-05099 PSG
11-22-2011
MARK HOLCOMB and KAY HOLCOMB, Plaintiffs, v. MACY'S, INC., MACY'S CREDIT AND CUSTOMER SERVICES, INC., DEPARTMENT STORES NATIONAL BANK and DOES 1-10, Defendants.
HANSON BRIDGETT LLP LAWRENCE M. CIRELLI, SBN 114710 EMILY M. CHARLEY, SBN 238542 Attorneys for Defendants MACY'S, INC., MACY'S CREDIT AND CUSTOMER SERVICES, INC., and DEPARTMENT STORES NATIONAL BANK Pierce Gore (SBN 128515) Kyla Holcomb Piramoon (SBN 263401) PRATT & ASSOCIATES The Pruneyard Tower I Attorneys for Plaintiff MARK HOLCOMB and KAY HOLCOMB
HANSON BRIDGETT LLP
LAWRENCE M. CIRELLI, SBN 114710
EMILY M. CHARLEY, SBN 238542
Attorneys for Defendants MACY'S, INC.,
MACY'S CREDIT AND CUSTOMER
SERVICES, INC., and DEPARTMENT
STORES NATIONAL BANK
Pierce Gore (SBN 128515)
Kyla Holcomb Piramoon (SBN 263401)
PRATT & ASSOCIATES
The Pruneyard Tower I
Attorneys for Plaintiff MARK
HOLCOMB and KAY HOLCOMB
JOINT STIPULATION AND [PROPOSED] ORDER FOR THIRTY-DAY EXTENSION OF TIME TO FILE AND SERVE JOINT RULE 26(F) REPORT
STIPULATION AND [PROPOSED] ORDER
Pursuant to FRCP 6(b) and Local Rule 6-1, plaintiffs Mark Holcomb and Kay Holcomb (collectively "Plaintiffs") and defendants Macy's Inc., Macy's Credit and Customer Services, Inc., and Department Stores National Bank (collectively "Defendants") through their undersigned attorneys, stipulate and respectfully request that this Court approve a thirty-day extension of time for the parties to file and serve a Joint Rule 26(f) Report, currently set for November 29, 2011. As grounds for this extension of time, the parties hereto state as follows:
1. Counsel for Defendants was only recently been retained and upon retention immediately sought, and was graciously granted, a thirty-day extension of time to respond to Plaintiff's complaint.
2. In order to properly evaluate the case and develop a thoughtful Discovery Plan, the parties believe a corresponding thirty-day extension to file and serve a Joint Rule 26(f) Report is necessary. Doing so will allow Defendants time to focus on responding to Plaintiff's complaint and evaluating the allegations before turning to the development of a Discovery Plan.
3. There have been no other time modifications in this case.
4. The parties believe this time modification will have very little impact, if any, on the schedule for this case given its early stage. To the contrary, the parties hope this extension of time will allow for a stream-lined and smooth case management moving forward.
NOW, THEREFORE, based upon the foregoing, the parties, through their undersigned attorneys, stipulate to extend the time to file and serve a Joint Rule 26(f) Report by thirty days, from November 29, 2011 to December 29, 2011.
IT IS SO STIPULATED between the parties.
PRATT & ASSOCIATES
Pierce Gore
Attorneys for Plaintiffs
MARK HOLCOMB and KAY
HOLCOMB
HANSON BRIDGETT LLP
Emily M. Charley
Attorneys for Defendants
MACY'S, INC., MACY'S CREDIT
AND CUSTOMER SERVICES, INC.,
DEPARTMENT STORES NATIONAL
and BANK
ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
___________________________
United States Magistrate Judge