Professional Documents
Culture Documents
1 Pursuant to Local Rule 7-1 and the Courts Standing Order 4 & 11, and as
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set forth in the Declaration of Peter A. Muhic, Plaintiffs Paul Stockinger, Elizabeth
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4 Stockinger, Gailyn Kennedy, Basudeb Dey, Brenda Flinn, and Eliezer Casper
5 (Plaintiffs) and Defendant Toyota Motor Sales, U.S.A., Inc. (Toyota), through
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their counsel, respectfully submit the following Stipulation to Extend Time:
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8 WHEREAS, Plaintiffs filed their Complaint against Toyota on January 3, 2017
9 and served Toyota on January 12, 2017, and pursuant to Local Rule 8-3, the parties
10 agreed to extend the deadline for Toyotas responsive pleading until March 3, 2017;
11 WHEREAS, Toyota filed its motion to dismiss the Complaint on March 3,
12 2017, and Plaintiffs response to the motion to dismiss is currently due on March 13,
13 2017;
14 WHEREAS, Plaintiffs intend to amend their Complaint under FED. R. CIV. P.
15 15(a)(1)(B), which provides for an amendment, as a matter of course, within 21 days
16 after the service of Toyotas motion to dismiss;
17 THEREFORE, good cause exists to grant this Stipulation in order to clarify
18 any conflict between Plaintiffs March 13, 2017 deadline to respond to the motion to
19 dismiss and the March 24, 2017 deadline for amending the Complaint under FED. R.
20 CIV. P. 15(a)(1)(B), and in order to provide the parties adequate time for briefing the
21 issues in this case, the parties hereby stipulate and agree to the following schedule:
22 1. Plaintiffs Amended Complaint shall be due no later than March 24,
23 2017;
24 2. Toyotas answer or motion to dismiss the Amended Complaint shall be
25 due no later than April 17, 2017;
26 3. Plaintiffs opposition to Toyotas motion to dismiss the Amended
27 Complaint shall be due no later than May 8, 2017;
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STIPULATION TO EXTEND TIME
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4. Toyotas reply brief in further support of the motion to dismiss the
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Amended Complaint shall be due no later than May 22, 2017; and
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5. Toyotas motion to dismiss the Amended Complaint will be heard on
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June 5, 2017, at 2:00 p.m.
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6 The parties respectfully request the Court enter an Order approving the above-
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schedule.
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9 IT IS SO STIPULATED
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11 Dated: March 13, 2017 Respectfully submitted,
12 KESSLER TOPAZ
13 MELTZER & CHECK, LLP
Joseph H. Meltzer
14 Peter A. Muhic
15 Melissa L. Troutner
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17 By: /s/ Peter A. Muhic
Joseph H. Meltzer
18 Peter A. Muhic
19 Melissa L. Troutner
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21 KIESEL LAW LLP
Jeffrey A. Koncius
22 Paul R. Keisel
23 Helen Zukin
24 Attorneys for Plaintiffs
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STIPULATION TO EXTEND TIME
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