Opinion
Case No: 5:11-cv-03228-EMC
11-04-2011
HEATHER NEWTON, individually and) behalf of others similarly situated, Plaintiff, v. AMERICAN DEBT SERVICES, INC., a California corporation; QUALITY SUPPORT SERVICES, LLC, a California limited liability company; GLOBAL CLIENT SOLUTIONS, LLC; ROCKY MOUNTAIN BANK AND TRUST; and DOES 1-100, Defendants.
RICHARD W. EPSTEIN (FLA. BAR NO: 229091) (Pro Hac Vice Admission Pending) REBECCA F. BRATTER (FLA. BAR NO: 0685100) (Pro Hac Vice Admission Pending) GREENSPOON MARDER, P.A. ROBERT S. BOULTER (SBN 153549) PETER C. LAGARIAS (SBN 77091) LAGARIAS & BOULTER, LLP Attorneys for Defendants Global Client Solutions, LLC and Rocky Mountain Bank and Trust
RICHARD W. EPSTEIN (FLA. BAR NO: 229091)
(Pro Hac Vice Admission Pending)
REBECCA F. BRATTER (FLA. BAR NO: 0685100)
(Pro Hac Vice Admission Pending)
GREENSPOON MARDER, P.A.
ROBERT S. BOULTER (SBN 153549)
PETER C. LAGARIAS (SBN 77091)
LAGARIAS & BOULTER, LLP
Attorneys for Defendants
Global Client Solutions, LLC and
Rocky Mountain Bank and Trust
CLASS ACTION
PLAINTIFF HEATHER NEWTON
DEFENDANTS GLOBAL CLIENT
MOUNTAIN BANK & TRUST'S
STIPULATION TO EXTEND
DEADLINE TO RESPOND TO
COMPLAINT ; ORDER
Pursuant to both L. R. 6-1(a) & 6-2, Plaintiff Heather Newton ("Plaintiff") and Defendants Rocky Mountain Bank & Trust ("RMBT") and Global Client Solutions, LLC ("Global") (collectively, "Defendants") (all, "Parties") file this Stipulation to Extend Defendants' Deadline to Respond to the Class Action Complaint from November 4, 2011 to November 7, 2011, and state as follows:
WHEREAS, according to the parties' Stipulation dated October 10, 2011 ("Initial Stipulation") [D.E. 19], Defendants' deadline to respond to the Class Action Complaint is November 4, 2011.
WHEREAS, after conferring with Counsel for Plaintiff, due to competing time demands, the Parties hereby stipulate that Defendants may have through November 7, 2011 to file their response(s) to the Class Action Complaint.
WHEREAS, furthermore, this Stipulation does not affect the other agreed-upon deadlines from the Initial Stipulation as Plaintiff shall still have through December 2, 2011 to file her opposition to Defendants' forthcoming motion and Defendants shall have through December 23, 2011 to file their reply.
WHEREAS, this Stipulation will not have an effect on the schedule for this case.
WHEREFORE, Plaintiff Heather Newton and Defendants Rocky Mountain Bank & Trust and Global Client Solutions, LLC stipulate to extend the deadline for Defendants to respond to the Class Action Complaint from November 4, 2011 to November 7, 2011.
Respectfully submitted,
GREENSPOON MARDER, P.A.
RICHARD W. EPSTEIN
(FLA. BAR NO: 229091)
(Pro Hac Vice Admission)
REBECCA F. BRATTER
(FLA. BAR NO: 0685100)
(Pro Hac Vice Admission)
LAGARIAS & BOULTER, LLP
ROBERT S. BOULTER (SBN 153549)
Attorneys for Defendants GLOBAL
CLIENT SOLUTIONS, LLC & ROCKY
MOUNTAIN BANK & TRUST
TAVY A. DUMONT SBN (244946)
LAW OFFICE OF TAVY A. DUMONT
Attorney for Plaintiff and Proposed Class
IT IS SO ORDERED:
Edward M. Chen
U.S. District Judge
CERTIFICATE OF SERVICE
I hereby certify that on this 4th day of November, 2011, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing.
Richard W. Epstein