Free Motion for Extension of Time to File Answer - District Court of California - California

Case 3:07-cv-02406-IEG-RBB

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Filed 05/20/2008

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Robert Jacobs, SBN 117676 [email protected] Mark B. Mizrahi, SBN 179384 [email protected] Don H. Min, SBN 221905 [email protected] BELASCO JACOBS & TOWNSLEY, LLP HOWARD HUGHES CENTER 6100 Center Drive, Suite 630 Los Angeles, California 90045 Telephone: (310) 743-1188 Facsimile: (310) 743-1189 Attorneys for Defendant Auto Page, Inc. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

DEI HEADQUARTERS, INC., Plaintiff, v. AUTO PAGE, INC. and ADVANCED SECURITY, INC., Defendants.

) CASE NO.: CV 07-2406 IEG (RBBx) ) ) Assigned ) Gonzalez to the Honorable Irma E. ) ) SECOND STIPULATION TO ) EXTEND TIME WITHIN WHICH ) DEFENDANT AUTO PAGE, INC. ) MUST ANSWER OR OTHERWISE ) RESPOND TO PLAINTIFF'S INITIAL ) COMPLAINT ) ) [Proposed] Order lodged concurrently ) herewith )

WHEREAS, plaintiff DEI HEADQUARTES, INC. ("DEI") served the initial complaint in this action on defendant AUTO PAGE, INC. ("API") on or about April 16, 2008; WHEREAS, the original deadline for API to answer or otherwise respond to the initial complaint in this action was May 6, 2008; WHEREAS, the parties previously stipulated to an initial fourteen (14) day extension of time for API to answer or otherwise respond to the initial complaint through and including May 20, 2008 and the Court granted said extension; and

Case 3:07-cv-02406-IEG-RBB

Document 11

Filed 05/20/2008

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WHEREAS, the parties are still engaged in settlement discussions with respect to the claims asserted in the initial complaint in this action.

IT IS HEREBY STIPULATED, by and between DEI and API, pursuant to Local Rules 7.2 and 12.1, that the time within which API must answer or otherwise respond to the initial complaint in this action shall be extended by an additional fourteen (14) days through and including June 3, 2008.

Respectfully submitted, Dated: May 20, 2008 BELASCO JACOBS & TOWNSLEY, LLP By: s/Don H. Min Robert Jacobs Mark B. Mizrahi Don H. Min Attorneys for Defendant Auto Page, Inc.

PAUL HASTINGS JANOFSKY & WALKER, LLP By: s/Sam Talpalatsky Sam Talpalatsky Attorneys for Plaintiff DEI Headquarters, Inc.

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Case 3:07-cv-02406-IEG-RBB

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Filed 05/20/2008

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PROOF OF SERVICE I am employed in the office of a member of the bar of this Court at whose direction such service was made. I am a resident of Los Angeles County, am over the age of 18 years and not a party to the within action. On May 20, 2008, I served the following document described as SECOND STIPULATION TO EXTEND TIME WITHIN WHICH DEFENDANT AUTO PAGE, INC. MUST ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S INITIAL COMPLAINT on the interested party(ies) in this action as follows: Stephen S. Korniczky, Esq. S. Christian Platt, Esq. Sam Talpalatsky, Esq. Trevor Q. Coddington, Esq. Paul, Hastings, Janofsky & Walker LLP 3579 Valley Centre Drive San Diego, California 92130 Attorneys for Plaintiff DEI Headquarters, Inc. Telephone: (858) 720-2500 Facsimile: (858) 720-2555

BY MAIL: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at Los Angeles, California, in the ordinary course of business. I am aware that, on motion of the party served, service is presumed invalid if postage cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. BY FACSIMILE: I served said document to be transmitted by facsimile to the above addressee(s) at the above-listed facsimile number(s). The sending facsimile machine issued a transmission report confirming that the transmission was complete and without error. BY FEDERAL EXPRESS: I served such envelope or package to be delivered for next day delivery by Federal Express upon the above addressee(s). BY HAND DELIVERY: I caused such envelope(s) to be delivered by hand to the office of the above addressee(s). VIA ELECTRONIC MAIL: This document has been served via electronic mail to the e-mail address set forth in the United States District Court for the Southern District's filing system. I declare that I am employed in the office of a member of the bar of this Court at whose direction such service was made. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on May 20, 2008, at Los Angeles, California. _____s/Patricia Anne McNulty Patricia Anne McNulty

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