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

Case 3:07-cv-02222-IEG-BLM

Document 34

Filed 08/29/2008

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1 AMAR L. THAKUR, CAL. BAR NO. 194025 JON E. MAKI, CAL. BAR NO. 199958 2 NICOLE M. LEE, CAL. BAR NO. 222344 CRYSTINA COATS, CAL BAR NO. 234301 3 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP A Limited Liability Partnership 4 Including Professional Corporations 12275 El Camino Real, Suite 200 5 San Diego, California 92130 Telephone: 858-720-8900 6 Facsimile: 858-509-3691 Email: [email protected] 7 [email protected] [email protected] 8 [email protected] 9 Attorneys for Plaintiff and Counterdefendant Bridgepoint Education, Inc. 10 11 12 13 14 BRIDGEPOINT EDUCATION, INC., 15 16 v. Plaintiff, CASE NO. 07 CV 2222 IEG (BLM) JOINT MOTION FOR EXTENSION OF TIME TO FILE DISMISSAL OF ACTION UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

17 PROFESSIONAL CAREER DEVELOPMENT INSTITUTE, LLC, and 18 DOES 1-10, inclusive, 19 Defendants.

Honorable Irma E. Gonzalez Courtroom 1

20 PROFESSIONAL CAREER DEVELOPMENT INSTITUTE, LLC, 21 Counterclaimant, 22 v. 23 BRIDGEPOINT EDUCATION, INC., 24 Counterdefendant. 25 26 27 28
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JOINT MOTION FOR EXTENSION OF TIME TO FILE DISMISSAL OF ACTION 07cv2222-IEG(BLM)

Case 3:07-cv-02222-IEG-BLM

Document 34

Filed 08/29/2008

Page 2 of 3

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WHEREAS, plaintiff and counterdefendant BRIDGEPOINT EDUCATION, INC.

2 ("BRIDGEPOINT") and defendant and counterclaimant PROFESSIONAL CAREER 3 DEVELOPMENT INSTITUTE, LLC ("PCDI"), (the "PARTIES") have been ordered to file their 4 joint motion for dismissal of this case by August 29, 2008; 5 WHEREAS, the attorneys of record have completed and approved the Settlement

6 Agreement resolving the action; 7 WHEREAS, certain PCDI client representatives who are needed to approve and sign the

8 Settlement Agreement are traveling or otherwise unavailable, in part as a result of the Labor Day 9 holiday; and 10 WHEREAS, BRIDGEPOINT will hold a meeting of the Board of Directors on Thursday,

11 September 4, 2008 at which time the Settlement Agreement can be ratified by the Board; 12 WHEREAS, the PARTIES hereby jointly seek an extension of time of seven (7) business

13 days to secure the required signatures and to file the dismissal in the action; 14 15 NOW THEREFORE, IT IS HEREBY RESPECTFULLY REQUESTED BY ALL

16 PARTIES TO THIS ACTION, THROUGH THEIR COUNSEL that this Court enter the 17 [Proposed] Order attached below to this Joint Motion, which Order provides for: 1) an extension 18 of time of seven (7) business days to file a dismissal of this action with prejudice, with each 19 PARTY to bear its own respective costs and attorneys' fees incurred in connection with this 20 action. 21 22 23 24 25 26 27 28
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JOINT MOTION FOR EXTENSION OF TIME TO FILE DISMISSAL OF ACTION

Case 3:07-cv-02222-IEG-BLM

Document 34

Filed 08/29/2008

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1 2 3 4 DATED: August 29, 2008 5 6 7 8 9 10 11 12 DATED: August 29, 2008 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
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IT IS SO AGREED AND REQUESTED.

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

By

s/ Jon E. Maki AMAR L. THAKUR JON E. MAKI NICOLE M. LEE CRYSTINA COATS Attorneys for Plaintiff and Counterdefendant BRIDGEPOINT EDUCATION, INC.

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

By

s/ Sarah M. Shalf SARAH M. SHALF JOHN E. FLOYD Attorneys for Defendant and Counterclaimant PROFESSIONAL CAREER DEVELOPMENT INSTITUTE, LLC

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JOINT MOTION FOR EXTENSION OF TIME TO FILE DISMISSAL OF ACTION